Iran trading – P&I cover – Update 22 March 2016 No.15-020 Download PDF (163KB) Introduction Members are referred to our Special Circular No.15-019 dated 22 February, 2016 and Japan P&I News No.807 dated 9 March, 2016 concerning Iran sanctions.  This Circular is intended to update members on the latest developments in relation to the interim and longer-term solutions to the reinsurance recovery shortfall risk under the Group General Excess Loss reinsurance programme and Hydra retrocession programme. Discussions with the US Administration Since the formal implementation on 16 January 2016 of the Joint Comprehensive Plan of Action (JCPOA) agreed between the P5+1 countries and Iran, the Group has been continuing its engagement with the relevant departments within the US government (the State Department and the Treasury Department’s Office of Foreign Assets Control (OFAC)) to discuss the P&I insurance ramifications of the implementation of the JCPOA. The implementation of the JCPOA in January 2016 resulted in the lifting of: The nuclear-related EU sanctions which had impacted Iran trade and the insurance thereof (with the exception of some continuing prohibited trades and trading by, and with, SDNs), and the nuclear-related US secondary sanctions, which impacted non-US person insurers/reinsurers. However, the US administration did not undertake under the JCPOA to lift, nor has it lifted, the primary US sanctions which prohibit the provision of insurance/reinsurance cover by US-domiciled reinsurers. Insurance cover solutions In its discussions with the US Administration, the Group has maintained its primary contention that it is in the policy interests of the US government that US-domiciled reinsurers should be licenced to participate on the Group and Hydra reinsurance programmes.  Over the next several months, the Group will be continuing its engagement with the Administration on this issue with the objective of securing a formal license to allow su