Iran- U.S./U.K. current and pending legislative action targeted at trading activities involving Iran 1 March 2010 No.09-019 The International Group (the Group) has been monitoring current and pending legislation in the US and the UK which would impose sanctions in relation to dealings with Iran and/or Iranian entities. There have been a number of recent developments which impact or will potentially impact on Members and on Club (P&I insurance); the following is summarized explanation for Members' guidance. 1. Current situation in respect of US/UKlegislation a)US Legislation-in respect of the refined petroleum products to Iran Even at the present moment, pursuant to the Iranian Transaction Regulations, unless licensed by the Office of Foreign Asset Control, goods, technology or services may not be exported, re-exported, sold or supplied from the US by US persons or companies wherever located to Iran or its government. Pursuant to US Executive Order EO13382, US persons and companies are prohibited from dealing with (including supply of the insurance) a number of Iranian shipping companies, including the Islamic Republic of Iran Shipping Lines ("IRISL"), which became Specially Designated National (SDN) designated by the US government authority. But such prohibition is targeted at the activities of identified Iranian companies and their vessels and does not extend to the wider shipping community. Of great concern is, in addition to the above restrictions, proposed legislation named "Iranian Refined Petroleum Sanctions Act"(=IRPSA, House Bill HR2194, and Senate Bill S908). These bills, if enacted, impose new trade sanctions focused specially on the exportation of refined petroleum products to Iran. Sanctions would apply in relation to the any vessel(s), regardless of country of flag/registry/beneficial ownership, trading refined products into Iran even where, as a matter of the law governing the relevant contracts of carriage, the adventure is lawful. Sanctions would