Iranian Transactions and Sanctions Regulations


In a judgement of 7 April 2020 (ECLI:NL:HR:2020:623), the Dutch Supreme Court confirmed that the EU Blocking Regulation (“EUBR”) does not prevent extradition of an Iranian national to the United States for their alleged involvement in US export controls and sanctions violations. With this judgement, the Supreme Court upheld the judgement of the District Court of Rotterdam of 5 July 2019 (ECLI:NL:RBROT:2019:5338).   This case was triggered by an extradition request for an Iranian national…

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 October 31, 2019, the US State Department strengthened US secondary sanctions targeting Iran under the Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”) (codified at 22 U.S.C. § 8801 et seq.), which dates back to 2013.  These new IFCA sanctions target the construction sector in Iran and make sanctionable the export to Iran of certain strategic metals.