Treasury has issued a notice explaining the effects on sanctions against Iran of Implementation Day (I Day) under the Joint Comprehensive Plan of Action (JCPoA). I Day was 16 January, on which date the EU simultaneously suspended or terminated nuclear related sanctions. As a result:
- 34 individuals and 298 entities are no longer subject to an asset freeze;
- there are no restrictions on financial transfers to and from non-listed Iranian entities, so there is no need to notify Treasury of them or seek approval for them;
- banking activities by Iranian banks in EU states are allowed;
- insurance and reinsurance can be provided to non-listed Iranian entities; and
- transactions in public or public-guaranteed bonds with Iranian non-listed entities are permitted.
Treasury notes several individuals and entities in and related to Iran are still Designated Persons because of human rights and terrorism concerns. Treasury made a new set of regulations, replacing the former statutory footing for UK financial sanctions. The changes took effect at 4:00pm on 18 January. For further information, and information on the US approach, see our separate article. (Source: Treasury Updates Iran Sanctions)