On 19th October 2018 the FATF decided to continue the suspension of counter-measure on Iran, due to the political commitment and relevant steps Iran has taken since June 2016 to address its strategic AML/CFT deficiencies. However, until the full action plan is going to be completed, Iran will remain on the FATF public statement.
So how will the EU “SPV” survive the Iran Deal?
The SPV would serve as a barter system not to be connected to the US dollar-denominated international financial system nor requiring monetary transfers between EU countries and Iran.
Credits for oil or goods imported from Iran by one EU firm could be used to pay an EU exporter for its goods or services to Iran, without any funds being sent to the Middle East.
EU is genuinely ready to live up to its promise to keep the so-called Iranian nuclear deal alive. Either France or Germany might become the host nation for the “SPV”. This barter exchange would be ultimately important for Iran in order to live up to their commitments under the JCPOA.
If you would like to discuss the impact of Iranian Sanctions on your business in more detail please contact Jaap van Dijk.