On 26th July 2010 Clyde & Co LLP published an article setting out the new Iran sanctions that had been adopted by the European Union Foreign Affairs Council. As part of our international offering we will be sending out regular bulletins written by our lawyers all over the world keeping you informed of the latest developments. This bulletin is the first in a series.
Background to the sanctions
On 9 June 2010 the United Nations Security Council (UNSC) passed Resolution 1929 (2010) imposing further UN sanctions on Iranian entities. A day later the UK responded by including within its own sanctions regime individuals and entities targeted by the UN. On 1 July 2010 the US enacted the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), which was followed on 26 July 2010 by the EU Foreign Affairs Council Decision, which together impose the toughest sanctions regime yet on Iran, with ramifications for the energy, insurance, transport and financial sectors. More recently on 16 August 2010 the US Treasury Department issued the Iranian Financial Sanctions Regulations to implement subsections 104(c) and 104(d) of CISADA.
Recent Developments in the news
On 18 August 2010 Barclays Bank PLC agreed to pay $298 million to settle US Sanctions claims, including charges that it breached the International Emergency Economic Powers Act and the Trading with the Enemy Act in dealings between 1995 and 2006. Sizeable settlements are no longer unusual, as Credit Suisse AG agreed in December 2009 to pay $536 million to settle allegations that it engaged in payment processes that prevented US banks from identifying the involvement of US Sanctions targets in funds transfers, and in January 2009 Lloyds TSB Bank agreed to pay $350 million to resolve allegations that it had assisted clients in Iran, Libya and Sudan to avoid US Sanctions.
It was reported in the UAE local news in July that the UAE has said that it is checking to see if it complies with the UN resolution. The UAE's Central Bank has already asked financial institutions to freeze 41 bank accounts of Iranian individuals and companies in compliance with the UN. This is an important area as the UAE is seen as the gateway to trade with Iran
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