29 July 2014 TO ALL MEMBERS Dear Sirs Iran Sanctions Circular on the Extension of Sanctions Relief under the Joint Plan of Action This Circular should be read in conjunction with the News Alert published on 29 January 2014 regarding the temporary relief of EU and US sanctions measures relating principally to transportation and insurance of petrochemical cargoes from Iran and Iranian crude to NDAA 1 waiver countries. By way of background, on 24 November 2013, China, France, Germany, the Russian Federation, the United Kingdom and the United States (the P5+1) reached an agreement with Iran on its nuclear programme and jointly published a Joint Plan of Action (JPoA) which included the implementation of a temporary suspension of certain transportation and insurance prohibitions measures for a period of six months with effect from 20 January 2014. Timing The six month temporary suspension period expired on 20 July 2014. Subject to the parties to the JPoA meeting certain conditions, it has been agreed that a further period of temporary suspension of prohibition measures will apply until 24 November 2014. The United States has issued FAQs and Guidance through the Office of Foreign Assets Control and Department for State. The European Union has issued Council Decision 2014/480/CFSP of 21 July 2014, but it has not amended implementing Regulation 2014/42/EU so this Regulation remains in force in its original form extended beyond 20 July 2014 to 24 November 2014. It should also be noted that the temporary suspension of prohibitions may be withdrawn and the prohibitions reinstated with immediate effect if the commitments and undertakings on the part of Iran in the JPoA are not fulfilled. General issues to note In reviewing the extension of the sanctions suspension measures discussed briefly below, two important points in relation to these measures should be borne in mind by shipowners and Clubs; 1 U.S. National Defence and Authorisation Act waivers are granted by the U.S. Administration to countries who have demonstrated a significant reduction in imports of Iranian oil. The most recent list of waiver countries is limited to India, China, Japan, South Korea, Taiwan and Turkey - 2 – (i) Period of suspension of current measures It is important to note that the extension of the suspension of sanctions measures is for a defined period until 24 November 2014. To the extent that shipowners wish to take advantage of the extension period and enter into transportation contracts, they are advised to ensure that all transactions under any contract/s will be fully executed by 24 November 2014 at the very latest. (ii) Transactions with Designated Entities The extension of the suspension of sanctions will not provide relief from the current prohibitions concerning transactions with U.S. and or EU designated persons or entities (identified on lists published by OFAC, the EU and HMT in the UK 2 ) What is the practical effect of the extension of the Joint Plan of Action on Insurance for Owners and Clubs? The wider position as regards insurance cover during the period up to 24 November 2014 is different in the U.S. and EU. US Following earlier engagement with the Group. the U.S. Department for State has now confirmed that “Insurance payments for claims arising from incidents that occur during the JPOA period and/or the extended JPOA period may be paid after November 24, 2014, so long as the underlying transactions and activities conform to all others aspects of the s