On 31 March 2020, the UK Foreign and Commonwealth Office (“FCO”) announced that the Instrument in Support of Trade Exchanges (INSTEX) had successfully concluded its first transaction. This transaction involved the successful export of medical goods from Europe to Iran, and paves the way for future transactions. In its announcement, the FCO stated: “Now the first transaction is complete, INSTEX and its Iranian counterpart STFI [(Special Trade and Finance Instrument)] will work on more transactions…
Representatives of China, France, Germany, Russia, the United Kingdom and Iran met on 26 February 2020 at a meeting of the Joint Commission of the Joint Comprehensive Plan of Action (JCPOA). All participants reaffirmed their commitment to the JCPOA and their strong support and collective responsibility for the continuation of key nuclear non-proliferation projects. The meeting follows the announcement on 14 January 2020 that the JCPOA Dispute Resolution Mechanism had been initiated by the E3 Foreign Ministers (see our earlier blog post here); the time limit for Joint Commission consideration of Iran’s actions was extended without a specific deadline at the end of January (extending the 15 day period that was triggered on 14 January).
On 30 January 2020, the Swiss Federal Council announced the first successful pilot transaction under the proposed Swiss Humanitarian Trade Arrangement (SHTA), a payment mechanism designed to enable the delivery of humanitarian goods to Iran. The SHTA was developed by Switzerland since autumn 2018 with the cooperation of relevant US and Iranian authorities, along with selected Swiss and interested banks. Once finally agreed and implemented, it will become the first US OFAC-consented humanitarian trade arrangement,…
On January 16, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released a new frequently asked question (“FAQ”) regarding Iran-related sanctions. This FAQ comes on the heels of the US Government’s recent issuance of Executive Order 13902 (“EO 13902”) on January 10, 2020, which expanded secondary sanctions to target the Iranian construction, mining, manufacturing, and textile sectors and those parties engaged in “significant transactions” or providing “material support” to any parties designated…