New European Union Measures against Iran - Council Decision 2012/35 dated 23 January 2012 - Frequently Asked Questions

Wednesday, 8th February 2012

The latest round of EU measures against Iran impacting on shipowners and insurers were published in Council Decision 2012/35 on 23 January 2012. Whilst the Decision has immediate effect on EU Member States, it will not be binding on individuals and corporations (including shipowners and clubs who may be subject to the terms of the Decision) until the Council Regulation has been issued. There is no current date set for the issue of the Regulation, but the indications are that this is unlikely to be published before early March. The Decision does however include express provisions relating to the performance and insurance of contracts to import, purchase or transport crude oil, petroleum products and petrochemical products concluded post-23 January 2012 and in relation to continuing performance of contracts concluded prior to that date and contracts ancillary thereto up to stipulated cut-off dates (1 May 2012 for petrochemical products and 1 July 2012 for crude and petroleum products). Pending publication of the Regulation it is not possible to definitively advise on the impact of the new measures though the Group has prepared FAQs (accessible via the PDF link below) to provide initial guidance to clubs and members on a number of key issues arising. These will be periodically updated as further issues arise and once the Regulation enters into effect.