Her Majesty's Treasury, in addition to documenting the delisting of 34 persons and 298 entities, explains, from a legislative standpoint, what happened when Implementation Day occured this weekend:
1. Implementation Day, within the meaning of the Joint Comprehensive Plan of Action
(JCPoA), occurred on 16 January 2016. Implementation Day was the date on which the
International Atomic Energy Agency (IAEA) reported on the agreed measures taken by Iran
under the JCPoA and as a result the EU simultaneously terminated (in some cases only
suspended) nuclear related financial and economic sanctions.2. On the 18 October 2015 (‘Adoption Day’, within the meaning of the JCPoA), the EU
adopted the legal acts to prepare for the lifting of nuclear-related economic and financial
EU sanctions on Implementation Day. These regulations have now come into effect.3. Council Regulation 2015/1861 of the Council of the European Union, amended Regulation
(EU) No 267/2012 by removing the prohibitions set out under paragraph 5 below. The
regulation can be found here: http://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:32015R1861&from=EN.4. Council Implementing Regulation 2015/1862 of the Council of the European Union,
similarly amended Regulation (EU) No 267/2012 by removing the restrictive measures from
certain individuals and entities. Details of the relevant individuals and entities can be found
in the Annex to this Notice. The regulation can be found here: http://eur-
lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32015R1862&from=EN.5. The key provisions of EU sanctions relief under the JCPoA are as follows:
- 34 individuals and 298 entities are no longer subject to an asset freeze. Full details
can be found in the Annex to this Notice. - The restrictions on financial transfers to and from non-listed Iranian entities have
ended. The requirement to seek prior authorisation for, or notify HM Treasury of,
transfers of funds sent to or received from Iran, is therefore no longer applicable. - Banking activities (such as the establishment of new correspondent banking
relationships with Iranian Banks and the opening of branches, subsidiaries or
representative office of Iranian Banks) in EU states are permitted. - The provision of insurance and reinsurance to non-listed entities Iranian entities is
permitted. - The supply of specialised financial messaging services is permitted for non-listed
Iranian financial institutions. - Transactions in public or public-guaranteed bonds with Iranian non-listed entities are
permitted.
6. Full information is provided in the Information Note on EU Sanctions to be lifted under the
JCPoA.7. United States (U.S.) secondary legislation imposing nuclear-related economic sanctions has
also been suspended as of Implementation Day. The Office for Foreign Assets Control has
issued guidelines with respect to the lifting of U.S. sanctions under the JCPoA. This guidance
can be found at the OFAC Iran Sanctions site.8. It should be noted that a number of individuals and entities remain subject to the restrictive
measures contained within Council Regulation 267/2012, and a number of Iranian entities
also remain listed for human rights and terrorism concerns.
Link:
Posted with BlogsyFiled under: EU Updates, HMT Updates, Iranian Sanctions, Sanctions Lists, Sanctions Regulations
