Iran Sanctions : A Brief Guide 1 July 2019 Royston Deitch Executive Representative, Head of IG Matters/General Manager of Underwriting Administration Dept. (Solicitor) This article is for general information only. Specific situations will need specific legal advice from suitably-qualified Counsel. There have been US sanctions against Iran since the hostage crisis in 1979 but the most recent story begins in 2015 with the Joint Comprehensive Plan of Action (JCPOA). Under the JCPOA, the five permanent members of the UN Security Council plus Germany and the EU on the one side, and Iran on the other, agreed that various US and EU sanctions against Iran would be lifted in return for Iran stopping its military nuclear programme. Donald Trump criticised the JCPOA during the 2016 US Presidential Election campaign and, having become President, on 8 May 2018 announced US withdrawal from it. 5 November 2018 thus brought “snapback”, a full re-imposition of sanctions lifted under JCPOA, and the restoration of secondary sanctions against non-US persons. Transactions involving crude oil and petroleum products, including transport and insurance, were targeted. US sanctions escalated on 8 May 2019 with the President’s Executive Order 13871 targeting Iran’s metals sector. Penalties for breaching sanctions are severe. The US’s OFAC (Office of Foreign Assets Control) imposes civil fines of the higher of USD 295,141 or twice the value of the transaction for each violation. There may be criminal penalties too, from the Dept. of Justice : fines of up to USD 1 million and 20 years in prison. In addition, assets may be blocked and a person added to the list of Specially Designated Nationals (SDNs). Shipowners negotiating a fixture and worried about instructions to go to Iran should ensure the charter allows them to refuse to comply with sanctions-related voyage orders. The BIMCO Sanctions Clause for Time Charter Parties gives owners this right. An express exclusion of Iran in the charter as