A merican Club Circular No. 41 /18 1 NOVEMBER 6, 2018 CIRCULAR NO. 41/18 TO MEMBERS OF THE ASSOCIATION Dear Member: REIMPOSED SECONDARY US SANCTIONS AGAINST IRAN COME INTO FORCE. SANCTIONS WAIVERS GRANTED TO CERTAIN COUNTRIES FOR THEIR PURCHASES AND IMPORTS OF IRANIAN CRUDE OIL. US TREASURY ADDS 700 IRANIAN SANCTIONS TARGETS TO THE OFAC SDN LIST. The reimposed sanctions November 4, 2018 marked the final day of the 180-day wind-down period following President Trump’s May 8, 2018 announcement to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA). Yesterday, November 5, 2018, the United States fully reimposed those sanctions on Iran that had been lifted or waived under the JCPOA. The sanctions which have been reimposed are summarized below: i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping Line Iran, or their affiliates; ii. Sanctions on petroleum-related transactions with, among others, the National Iranian Oil Company (NIOC), Naftiran Intertrade Company (NICO), and National Iranian Tanker Company (NITC), including the purchase of petroleum, petroleum products, or petrochemical products from Iran; iii. Sanctions on transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions under Section 1245 of the National Defense Authorization Act for Fiscal Year 2012; iv. Sanctions on the provision of specialized financial messaging services to the Central Bank of Iran and Iranian financial institutions described in the Comprehensive Iran Sanctions and Divestment Act of 2010; v. Sanctions on the provision of underwriting services, insurance, or reinsurance; and vi. Sanctions on Iran’s energy sector. Sanctions also include sanctions on associated services, related to the foregoing activities. A merican Club Circular No. 41 /1 8 2 The sanctions which were re-imposed as of August 6, 2018 comprise: i. Sanctions on the purchase or acquisition of US dollar banknotes by the Government of Iran; ii. Sanctions on Iran’s trade in gold or precious metals; iii. Sanctions on the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished, metals such as aluminum and steel, coal, and software for integrating industrial processes; iv. Sanctions on significant transactions related to the purchase or sale of Iranian rials, or the maintenance of significant funds or accounts outside the territory of Iran denominated in the Iranian rial; v. Sanctions on the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and vi. Sanctions on Iran’s automotive sector. The US Iran sanctions prohibit the American Club from engaging in the activities mentioned above. 1 It is also prohibited from providing insurance cover in connection with such activities. Oil purchase and import waivers The United States has also announced that it has granted waivers to the following jurisdictions for their purchases of crude oil from Iran, and to transactions by non-US persons related to such activity: China Greece India Italy Japan South Korea Taiwan Turkey 1 The Club’s EU-based Members are reminded that their compliance with US sanctions against Iran may constitute a violation of EU law under the EU Blocking Regulation which forbids compliance with US Iran and Cuba sanctions prohibitions. A merican Club Circular No. 41 /1 8 3