Emergency Contact IG Circular – Iranian trade after 4th November 2018 Home Latest updates News IG Circular – Iranian trade after 4th November 2018 23 Nov 2018 Download Sign up for alerts The Iran sanctions update circular issued on 29th May 2018 outlined the potential repercussions for shipowners and insurers arising from the U.S. Administration’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA) Agreement signed by China, France, Germany, Russia, the United Kingdom, the United States, the European Union (EU) and Iran.  The U.S. has now re-imposed sanctions on Iran that had been lifted or waived under the JCPOA with the second and final wind down period coming to an end on 4 th November 2018.   The U.S. has made it clear that it expects all non-U.S. persons to comply with the secondary sanctions that have been re-imposed.  The U.S. and the E.U. now take divergent approaches with the E.U. seeking to maintain the sanctions relief provided for by the JCPOA by, amongst other things, amending the annex to Council Regulation (EC) No 2271/96, otherwise known as the Blocking Regulation (see further European Union Regulation 2271/96 (Blocking Regulation) – Iran update  Circular). There are reports that eight countries - China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey - have or will be granted waivers from the U.S. so that they may continue to be permitted to import limited amounts of Iranian crude oil. The waivers do not extend to any other commodities. Limited guidance in relation to these waivers, or Significant Reduction Exemptions (“SREs”), is provided by OFAC FAQ 642.    It is further understood that countries holding SREs are being advised by the U.S. Administration to import Iranian crude only on NITC or IRISL vessels, or on vessels registered in the country holding the SRE and only where those vessels are insured under a sovereign guarantee issued by the Government holding the SRE. Followin