On 31 January, EU Foreign Ministers Jean-Yves Le Drian (France), Heiko Maas (Germany) and Jeremy Hunt (United Kingdom) announced the registration of the Instrument for Supporting Trade Exchanges (“INSTEX SAS”), a Special Purpose Vehicle designed to facilitate legitimate trade between European economic operators and Iran (press release available here). This comes after the joint announcement, in November 2018, affirming the EU’s commitment to maintaining financial channels with Iran after the US withdrawal from the JCPOA,…

On 29 January 2019, the UK Department for International Trade (DIT) published a notice (the “Notice”, available here) disclosing that, over the last 7 months, HM Revenue & Customs (HMRC) have issued compound penalties ranging between GBP 1,000 and 4,000 to 3 separate UK exporters related to unlicensed exports of dual use goods and export breaches. Further information on these penalties has not been released as none of the cases involved court prosecutions. Although the…

Following the snap-back of US sanctions on 5 November 2018, Foreign and Finance Ministers from the UK, France, Germany and the EU published a joint statement in which they expressed their “regret” at the re-imposition of sanctions on Iran by the US and also reiterated their “aim to protect European Economic operators engaged with legitimate business with Iran”. These comments suggest that the EU is determined to continue economic relations with Iran and that the…