Doing business with Iran : sanctions risks for the shipping and logistics sector
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1 Doing business with Iran : sanctions risks for the shipping and logistics sector Gerard Kreijen & Jochen Vankerckhoven LOYENS & LOEFF 1
2 Contents The lifting of EU sanctions against Iran The Iran sanction regime following the entry into force of the JCPOA: what is and what is not (yet) permitted? 90 Days 8 Years (or earlier if IAEA verifies peaceful activity) Trade controls: basic considerations Adoption Day 18 Oct Implementation Day 16 January 2016 Transition Day Est Termination Day Est The threat of US sanctions for EU exporters Parties needed to obtain approval in their respective jurisdictions. Parties made necessary arrangements for the implementation of JCPOA Parties implement sanctions relief after IAEA inspections Parties will terminate most remaining sanctions The impact of sanctions on the shipping and logistic sector Responsibilities Compliance Red flags Iran: Implementation commitments related to nuclear activities EU: Regulation lift nuclear sanctions on Implementation Day on simultaneous IAEA verification US: President to issue sanctions waivers in view of Implementation Day UN: Terminated sanctions after IAEA report EU: Nuclear related sanctions terminated or suspended (Annex II JCPOA) US: suspension of nuclear sanctions (Annex II JCPOA) Iran: ratifies additional protocol on IAEA inspections EU: terminates remaining sanctions US: terminates remaining sanctions UN: resolution terminating JCPOA 2
3 The lifting of EU sanctions against Iran (I) EU sanctions per sector Before implementation day After implementation day The lifting of EU sanctions against Iran (II) EU sanctions per sector Before implementation day After implementation day FINANCE, BANKING AND INSURANCE Transfers of funds to/from Iranian banks Prohibition Authorisations and notifications required for some transfers of funds to Iran Note that a limited number of banks will continue to be listed. Transfers to/from listed banks which remain listed, restrictions remain in force. FINANCE, BANKING AND INSURANCE Provision of insurance and Prohibition reinsurance Note that a limited number of banks will continue to be listed. Restrictions remain in force for transfers to/from banks which remain listed. Inter-bank relations vis-à-vis Iranian banks (opening new accounts, opening representation offices, establish new correspondent banking relations) Restricted for EU banks Specialised financial messaging services Prohibition (including SWIFT) to listed banks and other listed persons Note that a limited number of banks will continue to be listed. Restrictions remain in force for transfers to/from banks which remain listed., as regards de-listed banks and persons. Prohibition on providing SWIFT services will continue for listed banks until Transition Day. Business with Iranian government bonds ASSETS FREEZES Listed persons and entities Prohibition Requirement to freeze their funds Prohibition to make funds available to them Note that a limited number of persons and entities will continue to be listed, for which the measures remain in force until Transition Day. You may check the Consolidated EU Asset Freeze List. 3
4 The lifting of EU sanctions against Iran (III) EU sanctions per sector Before implementation day After implementation day The lifting of EU sanctions against Iran (IV) EU sanctions per sector Before implementation day After implementation day OIL, GAS AND PETROCHEMICALS Import or purchase of crude oil or Prohibition petroleum products which are located in or which originated in Iran; sales, supplies, exports of equipment and technology associated with those industries; and the provision of related financial assistance including insurance and re-insurance This prohibition was already suspended before Implementation Day. GOLD, PRECIOUS METALS AND DIAMONDS Sales, supplies, exports or transport of gold, Prohibition precious metals, or diamonds (and related services) This prohibition was already suspended before Implementation Day. SHIPPING, SHIPBUILDING AND TRANSPORT Export of certain naval equipment and Prohibition technology and services in respect of Iranian oil tankers and cargo vessels Note that some restrictions / prohibitions remain applicable in case of restricted / prohibited products. CURRENCY DELIVERIES Sale or supply of Iranian newly printed or Prohibition unissued denominated banknotes and coins to the Central Bank of Iran This prohibition was already suspended before Implementation Day. Supplying vessels designed for transporting or storing oil / petrochemical products to Iranian persons Prohibition This prohibition was already suspended before Implementation Day. GRAPHITE AND RAW OR SEMI-FINISHED METALS Sales, supplies, exports or transport of Prohibition specified graphite and raw and semi-finished metals to Iranian persons or for use in Iran (and related services) Restrictions Prior authorisation will still be required and will be decided on a case by case basis (taking the end use(r) into account) 4
5 The lifting of EU sanctions against Iran (V) EU sanctions per sector Before implementation day After implementation day Export controls SOFTWARE Sale of certain software to Iranian persons or for use in Iran Prohibition Restrictions Prior authorisation will still be required and will be decided on a case by case basis (taking the end use(r) into account) ARMS AND MILITARY RELATED MATERIALS Export to Iranian persons or for use in Iran of Prohibition goods and technology on the EU Common Military List (and related services) and import of such goods and technology DUAL USE AND OTHER CONTROLLED GOODS Import/export of dual use items and other Prohibition listed nuclear-related items to Iranian persons or for use in Iran Prohibition remains Will remain in force until Transition Day. In limited cases, authorisations for certain activities are possible. Restrictions Prior authorisation will still be required for exports and will be decided on a case by case basis (taking the end use(r) into account) 5
6 Trade controls 3 main categories Military controls (EU Common Military List) Dual-use controls (EU Regulation 428/2009 and Annex) Sanctions and embargoes EU Sanctions and Embargoes Basic categories Arms embargoes Embargoes on the import and export of certain goods, technology and software Financial restrictions such as asset freezes and prohibitions on the provision of funds and financial services Travel and visa restrictions for certain persons 6
7 EU sanctions and embargoes - Afghanistan - Ivory Coast - Tunisia - Al Qaida - Lebanon - USA - Belarus - Libya - Zimbabwe - Bosnia and Herzegovina - Moldova - Central African Republic - Myanmar (Burma) - China - North Korea - Congo (Democratic Republic) - Ukraine - Egypt - Russia - Eritrea - Serbia and Montenegro - Guinee (Conakry) - Sudan - Guinee-Bissau - Somalia - Haiti - South Sudan - Iraq - Syria - Iran - Terrorist groups Who must comply with EU sanctions and embargoes? EU Persons Any entity incorporated in an EU Member State and its EU and non-eu branches Any entity incorporated outside the EU in respect of business conducted in the EU Anyone (i.e., any director, officer, employee, agent, etc.) located within the EU irrespective of nationality Anyone (i.e., any director, officer, employee, agent, etc.) who is a national of an EU Member State even if located outside the EU Anyone on board any aircraft or vessel under the jurisdiction of an EU Member State 7
8 Extra-territorial reach of US trade controls Case study BelCo intends to provide machinery equipment to Iran Belgian US Belgian US Belgian Business operations and manufacturing facilities in Belgium 30% 70% 30% shareholder is CEO and controls day-to-day decisions US trade control regulations apply to US persons wherever they are US persons include all US citizens and permanent residents (i.e. green card holders) regardless of where they are located, all US incorporated entities and their foreign branches. For certain programs (Iran), foreign subsidiaries owned or controlled by US companies must also comply US trade control regulations can also apply to US goods or technology even if embedded in EU products USCo BelCo 30% shareholder has dual nationality Machinery includes inbuilt items sourced from the US US entity not involved in the business opportunities in Iran What sanctions risks are involved? 8
9 Business with Iran: caution remains! Impact of sanctions on the shipping and logistics sector Remainder of nuclear related sanctions (EU) EU sanctions with regard to human rights violations and military embargo still in place Screen for SDNs (US) and listed persons and entities (EU) EU export controls apply (items screening military and dual-use) Avoid payments in USD No involvement of US persons No US controlled content if 10% or more Focus on sanctions but keep in mind export controls Focus on EU sanctions but keep in mind the threat of US sanctions (Iranian Transactions and Sanctions Regulations (ITSR)) 9
10 Impact of sanctions on the shipping and logistics sector ITSR Impact of sanctions on the shipping and logistics sector Stricter than EU sanctions Prohibit US persons to transport cargo when (i) being (re)exported (directly or indirectly) to Iran or (ii) cargo has come into contact with Iran by being removed from a port, being processed through Iranian customs or by transiting Iran by train or truck to a destination outside Iran Also prohibits financing by US persons of Iran related transactions and dealings -> notable impact on non-us financial institutions and their support of Iran related financial transactions Responsibilities Compliance Red flags Why and how is the shipping and logistics sector targeted by sanction regimes? How to be compliant? What is an Internal Compliance Program? What in case of non-compliance? What are the red flags? 10
11 Responsibilities Why is the shipping and logistics sector targeted? Responsibilities How is the shipping and logistics sector targeted? Sanctions are focussing traditionally on the exporter or manufacturer of the goods Intermediaries facilitating international trade are however also targeted Financial intermediaries : banks, insurers, etc. Supply chain intermediaries : port operators, freight forwarders, carriers, ship owners Transport companies, freight forwarders, etc. already have been penalised for sanction and export control violations i. General prohibition to deal with SDNs / listed persons or entities Know your customer Knowledge of end-user Vessel or vessel owner can be listed Watch out for front entities 11
12 Responsibilities How is the shipping and logistics sector targeted? Responsibilities How is the shipping and logistics sector targeted? ii. Prohibition/restriction to assist with trade in prohibited or unauthorised cargo Usually express prohibition: to participate in activities circumventing sanctions (knowingly and intentionally) Potential violation by the transporter if actual knowledge or should know that it concerns prohibited trade (e.g. items will have military end-use (North-Korea sanctions)) If no express prohibition/restriction : still potential enforcement actions by authorities (delay of shipments, additional costs, etc.) iii. Certain transport specific prohibitions Prohibition/restriction to transport listed items (freight forwarders; transport companies) art. 2a; art. 3a (prior authorisation) and 4c (prohibition) of EU Regulation 267/2012 Prohibition to provide bunkering services to vessels or other servicing of vessels (port operators) art. 37 of EU Regulation 267/2012 (Chapter VI: Restrictions on transport) 12
13 Responsibilities How is the shipping and logistics sector targeted? iv. Service providers subject to pressure from exporters/clients to fulfil obligations under sanction regimes Exporters who seek to be compliant rely on their service providers: carriers, freight forwarders, etc. The more exporters follow a strict compliance program, the more they expect the same from their trade partners in the supply chain Compliance is good for business Responsibilities in a complex web of legal regimes Several sanction regimes (Iran; North-Korea; etc.) and export control regimes (dual-use; military; etc.) While being active in multiple jurisdictions (US, EU, UAE, Singapore, etc.) and in a changing landscape Transport sector evolving : more responsibilities / tasks in the supply chain and reducing shipping times Increased scrutiny of authorities (See US guidance for freight forwarders; Swiss authorities; EU authorities) Convergence of these pressures on the transport industry will not abate 13
14 Compliance How to be compliant? Insufficient is: merely contractual statement of exporter/customer that no prohibited trade is concerned Limited defence under EU sanctions : no liability if actor did not know, and had no reasonable cause to suspect, that actions would infringe sanctions BUT: sufficient due diligence and adequate controls to detect a breach required! Contractual statements useful to cover gaps in due diligence checks, e.g. lack of information Be careful for standardised contractual statements: e.g. sanctions against Russia contain specific end-use restrictions such as certain oil projects or dual-use goods if military end-use Compliance What are the key elements of an Internal Compliance Program (ICP)? Screening customer and other parties in the supply chain Checking cargo Receive sufficient and precise information from exporter If possible (high level) inspection of the goods Correlation between customs HS codes and dual-use ECCN codes Train your staff Indicate red flags and implement escalation steps when they show 14
15 Compliance Use of certification schemes Compliance What in case of non-compliance? Being a reliable business partner Seeking reliable business partners Why AEO-certification matters for sanctions and export control compliance Detection of the precise non-compliance issue Report to authorities? Improve your ICP Non-compliance does occur 15
16 Red flags Delivery address Goods classification Goods documentation Payments Export license Transit Destination country s industries (Re-)insurance Designated Parties Red flags 16
17 Where can you learn more? Read www. worldtradecontrols.com Or speak to us... Jochen Vankerckhoven, Attorney at Law jochen.vankerckhoven@loyensloeff.com Gerard Kreijen, Attorney at Law gerard.kreijen@loyensloeff.com 17
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