American Club Circular No. 01/13 1 JANUARY 07, 2013 CIRCULAR NO. 01/13 TO MEMBERS OF THE ASSOCIATION Dear Member: ADDITIONAL EUROPEAN UNION (EU) ECONOMIC SANCTIONS: IRAN Your Managers pass on herein news of recently implemented EU sanctions concerning Iran. Background On July 26, 2010, the Council of the EU approved Decision 2010/413/CFSP. This confirmed the restrictive measures taken by the EU against Iran since 2007, implemented the initiatives called for under UN Security Council Resolution 1929 (2010), and adopted new and additional economic sanctions against Iran. The sanctions contained in Decision 2010/413/CFSP mainly concern companies in the energy, transportation, financial and insurance sectors. By Decision 2012/635/CFSP of October 15, 2012, the Council amended the above mentioned Decision and promoted additional restrictive measures. On December 21, 2012, the Council further amended Decision 2010/413/CFSP and related Regulation (EU) No 267/2010 by adopting Decision 2012/829/CFSP and Regulation (EU) No. 1263/2012. These measures introduced new bans on exports and imports of certain products, clarified the prohibition of certain services with regard to Iranian oil tankers and cargo vessels, enhanced the monitoring of all activities of EU financial institutions with Iranian financial institutions, and modified the provisions on the freezing of funds and economic resources, including the listing of additional persons and entities as sanctions targets. Under EU law, the measures contained in Council Regulation (EU) No 1263/2012 of December 21, 2012 required further implementation. In order to ensure the uniform implementation, as well as the uniform application, of these measures by economic actors in all member states, the EU adopted Regulation (EU) No. 1264/2012 concerning restrictive measures against Iran. This was also accomplished on December 21, 2012. A brief overview of Regulation (EU) No. 1263/2012 and Regulation (EU) No 1264/2012 Prohibition on the purchase, import and transport of natural gas products The new Regulations’ restrictive measures include a ban on the import, purchase or transport of Iranian natural gas, and on the provision, directly or indirectly, of financial services, including insurance and reinsurance and brokering services related to insurance, with regard to the import, purchase, swapping and transport of natural gas. The new prohibitions mirror the existing prohibitions contained in Regulation (EU) No 267/2012 regarding oil, petroleum and petrochemical products. There are certain exceptions for contracts concluded before July 26, 2012 or October 16, 2012. American Club Circular No. 01/13 2 Bans on exports of certain products According to Regulation (EU) No 1263/2012, it is prohibited to export graphite, raw or semi-finished metals (e.g. aluminum and steel), key naval equipment and technology for ship-building, maintenance and refit as well as additional key equipment or technology for the Iranian oil, natural gas and petrochemical sector, from the European Union to any Iranian person. Furthermore, the sale, supply or transfer of software for certain industrial processes from the European Union to any Iranian person, or using EU-flagged vessels or aircraft, is illegal. Exports of certain dual-use items or technologies relevant to industries controlled by the Islamic Revolutionary Guard Corps, or for Iran’s nuclear program, remain prohibited; the respective annexes listing such items have been reviewed