Iran Sanctions Update: Joint Plan of Action Extended, Trade Officially Discouraged

Financial Sanctions: Iran (nuclear proliferation) - limited sanctions relief remains in place until 30 June 2015

The E3+3 (US, UK, France Russia, China and Germany) and Iran have been engaged in intensive negotiations to reach a comprehensive agreement on Iran's nuclear programme since February 2014. This was made possible by the agreement in November 2013 of the Joint Plan of Action (JPoA), under which Iran and the E3+3 committed to a number of measures in order to create the time and space for a comprehensive negotiation. 

The JPoA was extended from 20 July 2014 to 24 November 2014.  Talks have continued since then between the E3+3 and Iran.  These have made progress but significant gaps remain.  The E3+3 and Iran have therefore agreed to again extend the JPoA for a further seven months until 30 June 2015.

This means that the limited EU sanctions relief under the JPoA will remain in place until 30 June 2015. No additional sanctions have been suspended. All other EU sanctions and restrictions remain in place and in force. The UK government’s position remains not to encourage trade with Iran.

Further information on financial sanctions in place against Iran (nuclear proliferation) is available here.

Ukraine: HM Treasury Asset Freezing Now in Place

HM Treasury has today applied European Council Regulation (EU) 208/2014 which imposes financial sanctions, including asset freezes, against certain persons, entities and bodies in view of the situation in Ukraine. This was imposed by Council Regulation (EU) 208/2014 (“the Regulation”).

The Notice reads:

What you must do

You must:

  1. Check whether you hold any accounts, funds or economic resources for the persons set out in the Annex to this notice;
  2. Freeze such accounts, funds or economic resources; 
  3. Refrain from dealing with such accounts, funds or economic resources, or making them available to such persons - unless licensed by the Treasury;
  4. Report any findings to the Treasury, together with any additional information that would facilitate compliance with the Regulation;
  5. Provide any information concerning the frozen assets of such persons that the Treasury may request. Information reported to the Treasury may be passed on, for example to other regulatory authorities or law enforcement agencies.

Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

The list of target entities and individuals can be found here.

Chambers continues to advise on licensing arrangements, breaches and duties upon financial institutions.

Libya Asset Freeze and Sanctions Update (September 2011)

Following the National Transitional Council's installation as the de facto governing force in Libya, HM Treasury has amended its asset freezing provisions.

The move is good news for the Libiyan people and British business too. Restrictions on payments, debt/asset recovery and trade can now be lifted.

33 Chancery Lane have been directly instructed by UK businesses to advise on recovery solutions and sanctions.

Although the list has been relaxed in parts, it is still very important to seek advice when dealing with any transaction, individual or person subject to the restrictions. Breaching the provisions may result in a custodial sentence and high value confiscation proceedings.

Contact Martin Adams for further information.

Deletions from the Consolidated Prohibition List as of 02 September 2011.

  1. AL-SHARARA OIL SERVICES COMPANY a.k.a: (1) Al Sharara, (2) Al-shahara oil services company, (3) Al-Sharara al-Dhahabiya Oil Services Company, (4) Sharara, (5) Sharara Oil Services Company. Address: Al-Saqa District, Beside al-Saqa Mosque, Tripoli, Libya.
  2. AZZAWIA REFINING a.k.a: Azawiya Refining. Address: PO Box 6451, Tripoli, Libya
  3. BREG. Address: Head Office, Azzawia coast road, PO Box Azzawia 16649
  4. ECONOMIC AND SOCIAL DEVELOPMENT FUND (ESDF).  Address: Qaser Bin Ghasher Road, Salaheddine Cross, BP 93599, Tripoli, Libya
  5. FIRST GULF LIBYAN BANK. Address: The 7th of November Street, PO Box 81200, Tripoli, Libya
  6. GUMHOURI BANK. Address: Gumhouria Bank Building, Omar Al Mukhtar Avenue, Giaddal Omer Al Moukhtar, PO Box 685, Tarabulus, Tripoli, Libya.
  7. HAROUGE OIL OPERATIONS a.k.a: (1) Harouge, (2) Veba Oil Libya GMBH. Address: Al Magharba Street, PO Box 690, Tripoli, Libya
  8. JAWABY PROPERTY INVESTMENT LIMITED. Address: Cutlers Farmhouse, Marlow Road, Lane End, High Wycombe, Buckinghamshire,  United Kingdom
  9. LIBYAN ARAB AIRLINES. Address: PO Box 2555, Haiti Street, Tripoli, Libya
  10. MABRUK OIL OPERATIONS. Address: Dat El-Emad 2, Ground Floor, PO Box 91171, Tripoli, Libya
  11. MEDITERRANEAN OIL SERVICES COMPANY a.k.a: Mediterranean Sea Oil Services Company. Address: Bashir El Saadawy Street, PO Box 2655, Tripoli, Libya
  12. MEDITERRANEAN OIL SERVICES GMBH a.k.a: (1) MED OIL Office Duesseldorf, (2) MEDOIL. Address: Werdener strasse 8, Duesseldorf, Nordhein - Westfalen, Germany, 40227.
  13. NATIONAL COMMERCIAL BANK. Address: Orouba Street, AlBayda, Libya.
  14. NATIONAL OIL FIELDS AND TERMINALS CATERING COMPANY. Address: Airport Road Km 3, Tripoli, Libya
  15. NATIONAL OIL WELLS AND DRILLING AND WORKOVER COMPANY. a.k.a: (1) National Oil Wells Chemical and Drilling and Workover Equipment Co. (2) National Oil Wells Drilling and Workover Equipment Co. Address: National Oil Wells Drilling and Workover Company Building, Omar Al Mokhtar Street, PO Box 1106, Tarabulus, Tripoli, Libya.
  16. NORTH AFRICAN GEOPHYSICAL EXPLORATION COMPANY (NAGECO) a.k.a: North African Geophysical Exploration. Address: Airport Road, Ben Ghasir 6.7 KM, Tripoli, Libya.
  23. RAS LANUF OIL AND GAS PROCESSING COMPANY (RASCO). Address: Ras Lanuf Oil and Gas Processing Company Building, Ras Lanuf City, PO Box 2323, Libya.
  24. SAHARA BANK. Address: Sahara Bank Building, First of September Street, PO Box 270, Tarabulus, Tripoli, Libya.
  25. SIRTE OIL COMPANY. Address: Sirte Oil Company Building, Marsa Al Brega Area, PO Box 385, Tarabulus, Tripoli,  Libya.
  26. TAMOIL AFRICA HOLDINGS LIMITED a.k.a: Oil Libya Holding Company.
  27. TEKXEL LIMITED. Address: One Wood Street, London, United Kingdom.
  28. WAHA OIL COMPANY. Address: (1) Office location - Off Airport Road, Tarabulus, Tripoli, Libya. (2) Postal address - PO Box 395, Tripoli, Libya