A new deal
A joint statement by EU High Representative Catherine Ashton and Iran Foreign Minister Mohammad Javad Zarif reveals a phased plan that will see the gradual easing of sanctions against Iran, should all conditions be met.
The EU and E3+3 (China, France, Germany, the Russian Federation, UK and US) met on the weekend of 23 and 24 November 2013 to discuss a way forward and have agreed on the first step activities towards a final, comprehensive solution.
The joint plan of action requires Iran to downgrade its uranium enrichment program and importantly for the Iranians, includes international recognition of their country as a nuclear power, among other items.
Uncovering risk linked to Iran
Despite the negotiations and the potential change in sanctions, if your organization is in any way associated to companies with full or partial ownership based in Iran, or even companies that are associated with companies with Iranian origins, then you may be at risk of breaching sanctions.
Legislation such as CISADA remains unaffected during the first step activities, and this particular piece of legislation crucially places the onus on the organization to proactively conduct due diligence and know what information is available in the public domain on those with whom they do business.
There are also a significant number of US and EU sanctions that remain in place including US secondary sanctions against non-US banks for certain dealings with Iran, and the Iranian financial sector.
The following article entitled “MLROs should maintain ‘status quo’ on Iranian payments, despite deal, say lawyers” of November 27 provides useful insight into the ongoing situation.
MLROs should maintain ‘status quo’ on Iranian payments, despite deal, say lawyers
Money laundering reporting officers (MLROs) would be wise to maintain the status quo on Iranian transactions despite the proposed partial lifting of some sanctions against the country following historic talks at the weekend, according to lawyers.
Under the deal hatched in Geneva limits were placed on Iran’s nuclear programme in exchange for the relaxing of some sanctions against the state.
The deal is expected to unlock some $7 billion in oil revenue from the country. Officials from the U.S., the UK, China, France, Germany, and Russia pledged to not impose any new nuclear-related sanctions on Iran for six months and suspended existing sanctions on gold and precious metals.
There is also an indication that some $400m worth of Iranian investments would be released to help pay tuition fees for Iranian students abroad. Despite the easing of sanctions, widespread restrictions remain in place for the time being. This includes sanctions against Iranian banks and secondary sanctions imposed
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