Web-only circular issued by International Group clubs Updated 19 April and 25 May 2012 **************************** New European Union measures against Iran - Council Regulation 267/2012 dated 23 March 2012 - Frequently Asked Questions - issued on 27 March 2012 Background On 23 January 2012 The European Union Foreign Affairs Council agreed to introduce further measures impacting on trade that would or could support the furtherance of the Government of Iran's nuclear aspirations. Specifically the Council has introduced new measures to prohibit the trade and transportation of crude oil, petroleum products and petrochemical products. The new measures were set out in Council Decision 2012/35. On 23 March 2012 the Council issued Regulation 267/2012 implementing the provisions of the Decision and repealing Regulation 961/2010. The FAQs which follow, and which should be read in conjunction with the FAQs issued on 8 February 2012, cover the following current issues; The legal Status of EU Council Regulation 267/2012; The effect of the "grace periods"; Impact on the cover provided by clubs 1. What is the legal status of the Regulation? The Regulation is effective from 24 March 2012 and gives effect, subject to the modifications therein, to Council Decision 2012/35. It also repeals and replaces Regulation 961/2010. The provisions of the Regulation, in so far as these relate to the shipment of Iranian crude oil, petroleum and petrochemical cargoes and the insurance arrangements relating thereto, are effective from the dates stipulated in the Regulation, in particular in the provisions contained in Articles 11 – 14. 2. What is the effect of the "grace periods" provided for in Articles 12 and 14 in the Regulation? The Regulation reaffirms the two "grace periods" for the continuation of the performance of contracts which were concluded prior to 23 January 2012: (i) For petro-chemical products, until 1 May 2012, and (ii) For crude and petroleum products, until 1 July 2012. Th