In mid-October 2012, the EU adopted another round of sanctions against Iran so as to further increase pressure on Iran in relation to the development of a nuclear program[1].

Immediate entry into force of additional asset-freezing measures

The only measures to become binding immediately are the addition of one individual and thirty-four legal entities engaged in the oil and gas sector to the list of entities subject to asset freeze measures[2]. These entities include the Iranian Ministry of Energy and Ministry of Petroleum, as well as the National Iranian Oil Company. The new regulation also removed seven individuals and three entities from the list, including certain shipping companies. Further, on November 6, 2012, the EU added the Dutch subsidiary of the NIOC, National Iranian Oil Company Nederland, to the list of entities subject to financial sanctions[3].

Delayed implementation of further trade restrictions

The above mentioned Council Decision also seeks to introduce additional restrictive measures in the financial, trade, energy and transport sectors. In addition to the existing trade restrictions on Iran, the new measures would prohibit:

  • The purchase, import or transport from Iran of natural gas;
  • The sale, supply or transfer to Iran of aluminium and steel, graphite, raw or semi-finished metals and software for industrial processes;
  • The sale, supply or transfer to Iran of naval equipment and technology;
  • Involvement in the construction of new oil tankers for Iran;
  • All transactions between European and Iranian banks, unless authorized in advance under strict conditions with exemptions for humanitarian needs; and
  • The use of financial instruments such as short-term export credits, guarantees or insurance related to Iranian entities (medium- and long-term commitments were already previously prohibited).

The European Commission’s Implementing Regulation, which will probably be adopted later this month, will further define which specific products are included in each category mentioned above.

EU imposes stricter sanctions against Syria

The EU continues its policy of imposing measures targeting the Syrian regime and its supporters. In this context, the EU adopted new measures providing for a ban on the importation of arms and related materials, a ban on all flights operated by Syrian Arab Airlines as well as additional asset freezes targeting officials of the Syrian government[4].

In its Implementing Regulation, the EU added 28 officials of the Syrian government, two entities, and delisted two individuals and one entity to the list of entities subject to asset-freezing measures. As a result of this amendment, a total of 181 individuals and 54 entities are now subject to asset freezes under the EU Syria sanctions alone[5].

The new measures constitute the 18th round of sanctions since the beginning of the conflict in March 2011 and constitute an addition to the existing ban on exports to Syria of arms and related materials, telecommunications equipment and luxury goods, the ban on imports from Syria of oil and gas, and restrictions on financial services to Syrian entities.

France is expected to raise the possibility of lifting the ban on the supply of defensive arms equipment to Syria. This would allow the French defense industry to provide defensive armament to the Syrian opposition. Such a proposal will require discussion and agreement within the European Council.

EU adds names to the list of persons subject to asset freeze in Somalia

Also on October 16, 2012, the EU adopted restrictive measures against two individuals in Somalia and amending the information with regard to one individual[6]. The move reflects the decisions of the United Nations Security Council Committee made in July and August amending the UN list.


Companies with ties to the EU and trading with Iran, Syria and/or Somalia, whether directly or indirectly, should consider the following actions:

  1. Updating their database of sanctioned individuals and entities;
  2. Ensuring that none of their ongoing operations are covered by the new and/or planned sanctions; and
  3. Considering whether upcoming or proposed transactions are covered by the adopted and/or planned sanctions.