Web-only circular issued by International Group clubs Updated 25 May 2012 On 19 April 2012 the International Group of P&I issued an updated version of the FAQs originally published on 29 March 2012 New European Union Measures against Iran - Council Regulation 267/2012 dated 23 March 2012 - Frequently Asked Questions – issued on 19 April 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 Group has since corresponded and met with the UK Treasury to discuss the interpretation and application of the Regulation. The FAQs which follow, and which should be read in conjunction with the FAQs issued on 8 February 2012, substitute the FAQs issued on 27 March 2012 and cover the following current issues; The legal Status of EU Council Regulation 267/2012; The effect of the "grace periods"; Impact on shipowners, Impact on the cover provided by clubs It should also be noted that the FAQs address solely the ramifications of Council Regulation 267/2012 and do not address other nationally or internationally applicable sanctions measures which may impact on trade to and from Iran and the provision of insurance and reinsurance cover in relation thereto. 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