Economic Sanctions - Syria and Iran |
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In the United States Executive Order 13582 prohibits, among other things, “the importation into the United States of petroleum or petroleum products of Syrian origin” and “any transaction or dealing by a United States person, wherever located, including purchasing, selling, transporting, swapping, brokering, approving, financing, facilitating, or guaranteeing, in or related to petroleum or petroleum products of Syrian origin”. Executive Order 13590 authorises the US Secretary of State to impose financial sanctions in the US on any party who “sells, leases, or provides to Iran goods, services, technology, or support that has a fair market value of $1,000,000 or more or that, during a 12 month period, has an aggregate fair market value of $5,000,000 or more” and that could “directly and significantly” contribute to the development of Iran’s petroleum resources or domestic production of petrochemical products. The International Group reports that the US State Department has now clarified that EO 13590 "does not cover the purchase of petroleum resources or petrochemical products from Iran, or the shipping of those products from Iran, absent other sanctionable conduct". The International Group is continuing its dialogue with the State Department in respect of clarification on other aspects of the sanctions. 180 day Rule The House of Representatives has recently passed legislation to apply more stringent port entry requirements on ships that have previously traded in Iran, The Democratic People's Republic of Korea (DPRK) and Syria, which would bring policy on these countries more in line with the current policy on Cuba. The so-called “180 day rule” prevents vessels from entering ports in the United States if they have entered a port in Iran, North Korea, or Syria during the 180-day period preceding the arrival of the vessel in the United States. Further proposals would require vessels that have been in ports in Iran, North Korea or Syria in the preceding 12 months to be subject to enhanced inspections to determine whether the vessel was involved in any sanctioned activity.
EU sanctions on Syria restrict, among other things, the shipment of crude oil and petroleum products from Syria and the shipment of key equipment and technology for the oil and natural gas industries in Syria or to Syrian or Syrian-owned enterprises engaged in those sectors outside Syria. EU contacts have confirmed that the sanctions do not apply to petroleum and petrochemical products exported from the EU to Syria. Sanctions against Iran concentrate on the development of Iran’s nuclear capability, but also seek to restrict investment in the Iranian Oil and Gas industry, focusing primarily on the supply of materials to that sector. There is currently no restriction on import or export of oil and gas to and from Iran, although talks are underway which could lead to such restrictions being imposed in the near future. Our understanding is that the sanctions do not currently apply to shipments of vegetable oils and animal fats. |