The European Commission announced on 18 May 2018 that it would amend its Blocking Regulation to protect EU companies from the extraterritorial effects of US Iran sanctions reimposed after the US withdrew from the JCPOA (previous blog). This week (6 June 2018) the Commission published an amended version of the Blocking Regulation (see Regulation here and Annex here) (Council Regulation (EC) No 2271/96 of 22 November 1996) and the European Investment Bank (EIB) External Lending Mandate.
The explanatory memorandum explains that “some of the measures which the United States will reactivate against Iran have extra-territorial effects and… violate international law and impede the attainment of the Union’s objectives”. The EU will therefore amend the Regulation that previously related to the US’s Cuba and Libya measures to include Iran. The update to the EIB’s External Lending Mandate would make Iran eligible for investment activities by the EIB.
The European Parliament and the Council will now have 2 months for any objections to these measures before they enter into force. If there are none, the updated Blocking regulation will enter into force at the latest at the beginning of August 2018, by the time the first set of re-imposed US sanctions will take effect.