E3/EU+3 EXTENDS IRAN SANCTIONS RELIEF FOR FURTHER 3 DAYS

The E3/EU+3, comprising China, Russia, France, Germany, the UK, and the United States, have extended sanctions relief on Iran for a further 3 days until 10 July 2015 in order to continue their negotiations over a comprehensive solution to Iran’s nuclear program, aimed at ensuring its purpose is strictly peaceful.  This is the fourth time the sanctions relief has been extended, following the recent extension from 30 June until 7 July on the same basis (see previous blog).

US State Department spokeswoman Marie Harf announced that “substantial progress” had been made in recent days, and added that “we’re frankly more concerned about the quality of the deal than we are about the clock”.  French Foreign Minister Laurent Fabius has told reporters that there are 3 main sticking points, “limitations on nuclear research and development, sanctions and their reestablishment, and the possible military dimensions” of previous Iranian nuclear research.  Yesterday, a Western official also stated that “the Iranians want the ballistic missile sanctions” to be lifted, but “there’s no appetite for that on our part”, and Russian Foreign Minister Sergei Lavrov has said today that a UN arms embargo against Iran is a “major problem”.

The sanctions relief is set out in the November 2013 Joint Plan of Action (JPOA), and eases US and EU sanctions on Iran’s petrochemical exports, gold, and precious metals, eases US sanctions on Iran’s auto-industry, licences the supply and installation of certain parts and services to Iran’s aviation industry, prohibits further UN, EU, or US nuclear-related sanctions, establishes a financial channel to facilitate humanitarian trade with Iran, and increases the monetary threshold for transactions involving Iran before they have to be authorised.

The US Treasury’s guidance on the extension of sanctions relief is here and HM Treasury’s guidance on thresholds for prior notification of Iran transfers, which remain the same, is here.  The related EU decision is here.

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About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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