Iran faces re-imposition of sanctions following the 180 day wind-down period which ended on 4 November 2018 due to the U.S. government re-imposed sanctions that were relieved pursuant to the JCPOA (after a first set of sanctions had already be re-imposed per 6 August). As such, sanctions on Iran’s energy sector, Iran’s port operators, shipping and shipbuilding, as well as petroleum-related transactions have been re-introduced. In addition, on 5th November 50 Iranian banks and their foreign and domestic subsidiaries were designated under the SDN List; published by OFAC.
However some countries have received a waiver from the U.S., eight countries — including Japan, India and South Korea – are able to continue buying Iranian oil after it reimposed sanctions on the OPEC producers
EU Blocking Statute
To note, as of 7 August 2018, under this Blocking Statute EU persons are forbidden to comply with extra-territorial sanctions imposed by another state, unless exceptionally authorized by the European Commission to do so. EU operators can ask for recovery of damages arising from extra-territorial sanctions (such as those of the U.S.), e.g. if they are confronted with penalties.
If you are interested in finding out more on Iranian Sanctions and how they will impact your business you then please reach out to Jaap van Dijk