US/EU Iranian sanctions regime explained
Lawyers in the US hope the ongoing regulatory money laundering investigations will encourage a broader tightening of Iranian sanction regimes. Vandenberg & Felieu’s New York-based managing partner Raymond Vandenberg said there was a perception in the US that some of the regulators had accepted sanctions only ostensibly. “The US has a fairly moralistic view of things, and has consequently imposed a full-blown enforcement of sanctions against Iran applicable to most individuals and businesses whatever the size or type,” he said. “Whereas in Europe, and other parts of world geographically closer to Iran, there’s more of a temptation not to impose sanctions so fully because of the impact doing so will have on key business needs, for oil for example.”
Taylor Wessing’s Shane Gleghorn said Switzerland’s approach in particular had left scope for some Iranian oil transactions to fall through a regulatory gap in Europe. In July, the Swiss government announced a ban on supplying equipment to the Iranian petrochemical industry. But exempted transactions involving Iranian oil and petrochemical products for foreign policy reasons. Such deals are instead subject to a declaration requirement and thereby do not jeopardise Geneva’s significant role in oil trading. Gleghorn said there had been quite a bit of criticism of the Swiss approach by commentators in the US. “There are some commentators who suggest that there is, in some EU states, a practical difference between the US and EU approach because, from the US perspective, some of the states in the EU fail to enforce the sanctions regime with sufficient vigour,” he said.
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