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…
On 1 December 2019, it was announced that six more countries – Belgium, Denmark, Finland, Netherlands, Norway and Sweden – had signed up to the clearing house, Instex, joining France, Germany and the UK. Based in Paris, Instex functions as a clearing house that allows Iran to continue to sell oil and import other products or services in exchange. A joint statement by the existing shareholders, France, Germany and the UK, welcomed the development stating…
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.