US sanctions against Iran
The decision by President Trump announced on 8 May, 2018 to cease the US participation in the JCPOA and to begin re-imposing US nuclear-related sanctions which were lifted to implement the JCPOA, is likely to have significant ramifications for maritime trade with Iran and the insurance of such trade.
The US Department of the Treasury FAQs issued on 8 May relating to the effect of the re-imposition of US secondary sanctions measures, can be accessed via the ducument below;
The Group is already engaged with OFAC directly seeking clarification on a number of aspects of the application of the Presidential Memorandum of 8 May including in relation to the continuation of pre-8 May contractual obligations during the “wind-down” period, permitted trade with Iran after the 6 August and 4 November deadlines and in relation to the wind down of the General Licence H arrangements applying to non-US domiciled affiliates and subsidiaries of US domiciled insurers and reinsurers.
As the remaining JCPOA partners have reaffirmed their support for the JCPOA, the Group is also engaging with the UK Treasury and with the EU External Action Service in relation to the impact of the US decision, and possible EU measures, on the Clubs and their reinsurers. The position may become more complex in the short-term by virtue of the continued support for the JCPOA by its other signatories and by the recent threat of further sanctions being imposed by the U.S. The U.S. position has reverted to that prior to the relaxation of U.S. nuclear related sanctions on Implementation Day on 16 January 2016 when the JCPOA took effect. Shipowners and charterers who are considering trading to Iran should understand that P&I cover for such trade is unlikely to remain in place where there is a risk that providing insurance risks the imposition of sanctions by the U.S.
Read the full Circular in the below document.
P&I Circular 2635/2018 – US sanctions against Iran.pdf
All the clubs in the International Group has issued a similar circular.