On 24 March EU issued the latest round of sanction measures against Iran implementing Council Decision 2012/35 (23 January 2012) by way of Council Regulation 267/2012 (hereafter Regulation). The material provisions of the Regulation substantially reflect the corresponding provisions in the Council Decision.

The Regulation applies:
• Within the EC territory
• Onboard vessels under jurisdiction of any EC state
• To any person inside EC who is a national of a EC state
• To any legal person incorporated under the law of any EC state
• To any legal person in respect of any business done in whole or in part within the EC

The main features of the Regulation are as follows:
a. Prohibition to sell, supply, transfer or export directly or indirectly certain listed goods to any Iranian persons or for use in Iran
b. Prohibition to transport petroleum and petrochemical products originating from Iran or being exported from Iran
c. Prohibition to insure the transportation of petroleum and petrochemical products originating from Iran or being imported from Iran
d. Restrictions of transfer of funds to and from Iran
e. Restrictions on financing of certain enterprises

Of particular importance to the Club and its members are (b) and (c). Members are required to pay due attention to the following:

Prohibition to transport petroleum and petrochemical products
The Regulation prohibits the transportation of petroleum and petrochemical products of Iranian origin or if the product is being exported from Iran to any other country. However, provided proper notification is made it may be possible to perform contracts relating to transportation of petroleum products until 1 July 2012 and contracts relating to transportation petrochemical products until 1 May 2012. Members are recommended to obtain legal advice in order to ascertain to what extent they are subject to provisions of the Regulation.

Prohibition to insure transportation of petroleum and petrochemical products
The Swedish Club, being incorporated in Sweden, is subject to the provisions of the Regulation and, consequently, the insurance prohibitions. The same grace periods apply to the insurance prohibitions as for the transport prohibitions. Hence, the Club is unable to provide P&I insurance in relation to the transportation of Iranian petroleum products after 1 July 2012 and Iranian petrochemical products after 1 May 2012. This means that members will have no P&I cover after those dates in relation to any such transportation with reference to, inter alia, P&I Rule 11:4.

Regarding the wording of the Regulation please see the link “Council Regulation 267_2012 Iran sanctions” below.

Please find below also FAQs provided by the International Group of P&I Clubs.