29 May 2018 TO ALL MEMBERS AND ASSUREDS Dear Sirs Iran Sanctions The decision by President Trump announced on 8 May, 2018 to cease the US participation in the JCPOA and to begin re-imposing US nuclear-related sanctions which were lifted to implement the JCPOA, is likely to have significant ramifications for maritime trade with Iran and the insurance of such trade. The US Department of the Treasury FAQs issued on 8 May relating to the effect of the reimposition of US secondary sanctions measures, can be accessed via the web link below which can be accessed here. The Group is already engaged with OFAC directly seeking clarification on a number of aspects of the application of the Presidential Memorandum of 8 May including in relation to the continuation of pre-8 May contractual obligations during the “wind-down” period, permitted trade with Iran after the 6 August and 4 November deadlines and in relation to the wind down of the General Licence H arrangements applying to non-US domiciled affiliates and subsidiaries of US domiciled insurers and reinsurers. As the remaining JCPOA partners have reaffirmed their support for the JCPOA, the Group is also engaging with the UK Treasury and with the EU External Action Service in relation to the impact of the US decision, and possible EU measures, on the Clubs and their reinsurers. The position may become more complex in the short-term by virtue of the continued support for the JCPOA by its other signatories and by the recent threat of further sanctions being imposed by the U.S. The U.S. position has reverted to that prior to the relaxation of U.S. nuclear related sanctions on Implementation Day on 16 January 2016 when the JCPOA took effect. Shipowners and charterers who are considering trading to Iran should understand that P&I cover for such trade is unlikely to remain in place where there is a risk that providing insurance risks the imposition of sanctions by the U.S. - 2 Calls at Iranian ports One potential ramification of the US withdrawal from the JCPOA could be that, in the event of ship detention, Clubs could encounter difficulties putting up security in the context of any claim with an Iran nexus. This is particularly relevant if security is required for a major claim relating to Iranian port, since the U.S. will re-impose sanctions against Iran’s port operators, which sanctions provide for penalties against any person who provides “significant financial, material, technological, or other support to, or goods or services in support of any activity or transaction on behalf of or for the benefit of...a person determined to operate a port in Iran.” The ramifications of the re-imposition of secondary sanctions against Iranian ports are uncertain and we are seeking clarification from OFAC on this point. The position in relation to calls at Iranian ports under pre-8 May contracts during the wind down period up to 6 August and 4 November 2018 is unclear in a number of respects on which the IG is awaiting clarification and/or guidance from OFAC. Due to the uncertainty surrounding the application of the re-imposed secondary sanctions against Iranian ports, caution should be exercised in respect of all calls at Iranian ports, especially if they are made under post-8 May contracts and under all transactions after November 4, 2018. Due diligence should be exercised to ensure that neither the cargoes carried nor the parties involved in the transactions offend U.S. sanctions. However, we emphasise that t