DECISION 2012/635 ("DECISION")
On 15 October 2012, further restrictive measures were announced
by the EU against Iran. They are to be found in the European
Council Decision 2012/635/CFSP.
IS THE DECISION BINDING?
The only measures to become binding immediately are the
additions to the asset freeze list, via Regulation 945/2012. An
implementing regulation is required to make the other measures
binding on companies and individuals. The timing of that
implementing regulation is unclear – it could be weeks or
even months. It may be that the EU is firing a "warning shot
across the bows" and hoping to encourage Iran to return to the
negotiating table if they wish to avoid the new provisions actually
coming into force.