A merican Club Circular No. 15/18 1 MAY 10, 2018 CI RCULAR NO. 15/18 TO MEMBERS OF THE ASSOCIATION D ear Member: U NITED STATES WITHDRAWS FROM JCPOA AND REIMPOSES SECONDARY SANCTIONS AGAINST IRAN O n May 8, 2018, President Trump decided to withdraw the United States from participation in the JCPOA – the multipartite nuclear deal with Iran also involving Russia, China, France, Germany, the United Kingdom and the European Union. As a consequence, the United States has reimposed (“snapped back”) nuclear (or US secondary) sanctions against Iran which had previously been lifted as part of the deal. The May 8 decision will have a significant impact on maritime trade with Iran, and the insurance of such trade. The reimposed secondary sanctions target non-US persons engaged in certain activities with Iran. Non-US persons who may be affected by the reimposed US sanctions will, depending on the type of activity, have 90 and 180 days to mitigate the effects of the reimposed sanctions and wind down their sanctionable activities. Certain licenses under the primary sanctions against Iran, such as General License H authorizing foreign subsidiaries of US entities to engage in prohibited activities involving Iran, will be revoked, and activities must be wound down by November 4, 2018. A n FAQs document, published on May 8 (copy attached) by the US Treasury Department’s Office of Foreign Assets Control (OFAC), which administers and enforces sanctions, lists and briefly describes the full array of activities for which sanctions have been reimposed along with information regarding relevant wind down periods for such activity. For example, and of particular interest to the maritime sector, the May 8 decision provides for a 180 day wind down period which ends on November 4, 2018, with respect to activities and transactions involving: •I ran’s ports operators, and shipping and shipbuilding sectors; IRISL and South Shippi ng Li ne. •pet roleum-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. •t he provision of underwriting services, insurance, or reinsurance. * Q uestions and further guidance T he American Club, and the International Group of P&I Clubs of which it is a member, will continue to closely monitor developments with respect to the implementation of the reimposed sanctions and provide further guidance as necessary. A merican Club Circular No. 15/1 8 2 Members are reminded that, pursuant to American Club rules, there is no cover for unlawful voyages or for voyages where the extension of cover would violate, or pose a risk of violating, sanctions prohibitions, and also where causing a violation could entail the imposition of sanctions or penalties. Members are accordingly reminded to proceed with extreme caution in dealing with or involving Iran and Iranian entities and to conduct additional sanctions compliance due diligence to ensure their own, and the American Club’s, compliance with applicable sanctions prohibitions. Should Members wish to discuss any questions, or need additional guidance regarding any aspect of the foregoing or other sanctions in general, or for confirmations as to the availability of cover for voyages involving countries (Iran, Syria, Cuba, North Korea, Russia, the Crimea region of Ukraine, Venezuela (presently only SDNs)) or