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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…

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.