Iran Sanctions Update – May 2012

On 24 March 2012, EU Council Regulation No. 267/2012 ("the Regulation") entered into force in the EU (the day of its publication in the Official Journal). It repealed and replaced EU Regulation 961/2010, which had previously served as the main EU Regulation concerning restrictive measures against Iran.

This Regulation had been long awaited by those involved in international trade and, in particular, those in the shipping and insurance industry following the publication of EU Council Decision 2012/35/CFSP of 23 January 2012 ("the Decision"), which imposed restrictions on dealings with Iranian crude oil, petroleum and petrochemical products.

EU Decisions are only binding on those parties to whom they are addressed, in this case the EU Member States. In order to be binding against EU individuals and companies, the restrictions set out in the Decision needed to be incorporated into a Regulation. Prior to the publication of the Regulation, it was not entirely clear how,