On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many…
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…
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…
On 27 February 2020, the Swiss Humanitarian Trade Arrangement (SHTA), a payment mechanism designed to enable humanitarian goods to be delivered to Iran, came into effect. The SHTA was developed by Switzerland in close cooperation with the relevant authorities in the USA and in Iran, as well as with selected Swiss banks and companies. The SHTA is available to Swiss firms only. Following the US’s withdrawal from the JCPOA in May 2018, and the subsequent…