Iran Sanctions Update: Significant Reduction Exemptions

As reported in Circular 16/18 when U.S. secondary sanctions were re-imposed against the purchase and carriage of Iranian crude oil, petroleum products, liquified gases and petrochemicals, in November 2018, eight countries - China, Greece, India, Italy, Japan, South Korea, Taiwan, and Turkey - were granted waivers, known as Significant Reduction Exemptions ("SREs"), to permit the import of limited amounts of Iranian crude oil up to 2 May 2019.

Members should be aware that the U.S. State Department has announced that these SREs will not be renewed beyond 2 May 2019. In a further clarification provided to the Club's US legal advisors, the State Department has advised that voyages with shipments pursuant to the existing SREs must be completed within that 2 May deadline. Any purchase or carriage of Iranian crude cargoes after 2 May 2019 is therefore likely to be treated as a breach of U.S. sanctions, with all the risks which that involves.