JCPOA Implementation Day Guidance: Insurance

B. Sanctions Related to Insurance

Commitment:

Section 4.2 of Annex II and section 17.1 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons who provide
underwriting services, insurance, or re-insurance in connection with activities consistent with the
JCPOA, including activities with individuals and entities set forth in Attachment 3 to Annex II of
the JCPOA.

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

Correspondent or Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI)
27; section 1244(d)(2) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of significant
goods or services used in connection with the energy, shipping, or shipbuilding
sectors of Iran, including NIOC, NITC, and IRISL); and section 1247(a) of
IFCA.
2

b. Revoked E.O. 13645, including the correspondent or payable-through account
sanctions under subsection 3(a)(i) (for significant transactions by FFIs on behalf
of any Iranian person on the SDN List or any other person included on the SDN
List whose property and interests in property are blocked pursuant to subsection
2(a)(i) of E.O. 13645 or E.O. 13599).
2

c. Committed to refrain from imposing sanctions under sections 561.203(a) of the
Iranian Financial Sanctions Regulations, 31 C.F.R. part 561 (IFSR), for
transactions by FFIs with the CBI that are consistent with the waiver of section
1245(d)(1) of NDAA 2012.

Blocking Sanctions:

a. Waived the imposition of blocking sanctions under section 1244(c)(1) of IFCA30
(with respect to non-U.S. persons who knowingly provide significant financial,
material, technological, or other support to, or goods or services in support of any
activity or transaction on behalf of or for the benefit of a person determined to be
part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in
Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the
JCPOA).
31

b. Revoked: E.O. 13622, including the blocking sanctions under section 5(a) (with
respect to persons who have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, NIOC,
NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran); and E.O. 13645, including the blocking
sanctions under subsection 2(a)(i) (with respect to persons who have materially
assisted, sponsored, or provided financial, material, or technological support for,
or goods or services to or in support of, any Iranian person included on the SDN
List or any other person included on the SDN List whose property and interests in
property are blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O.
13599).
41

3. Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under:

i. Section 5(a) of ISA (with respect to non-U.S. persons who: make
investments above specified thresholds that could directly and
significantly contribute to the maintenance or enhancement of Iran’s
ability to develop petroleum resources; knowingly sell, lease, or provide to
Iran goods, services, technology, information, or support that could
directly and significantly facilitate the maintenance or enhancement of
Iran’s domestic production of refined petroleum products; sell or provide
to Iran refined petroleum products or sell, lease, or provide to Iran goods,
services, technology, information, or support that could directly and
significantly contribute to the enhancement of Iran’s ability to import
refined petroleum products; knowingly participate in certain joint ventures
for the development of petroleum resources outside of Iran; knowingly
sell, lease, or provide to Iran goods, services, technology, information, or
support that could directly and significantly contribute to the maintenance
or enhancement of Iran’s ability to develop petroleum resources located in
Iran or domestic production of refined petrochemical products; knowingly
sell, lease, or provide to Iran goods, services, technology, or support that
could directly and significantly contribute to the maintenance or expansion
of Iran’s domestic production of petrochemical products; own, operate, or
control, or insure a vessel used to transport crude oil from Iran to another
country; or own, operate, or control a vessel used in a manner that
conceals the Iranian origin of crude oil or refined petroleum products
transported on the vessel);

ii. Section 212(a) of the TRA (with respect to non-U.S. persons who
knowingly provide underwriting services or insurance or reinsurance for
NIOC, NITC, or a successor entity to either company, in cases where the
transactions are for activities described in sections 4.2, 4.3, and 4.4 of
Annex II of the JCPOA);

iii. Section 1244(d)(1) of IFCA (with respect to non-U.S. persons who
knowingly sell, supply, or transfer to or from Iran significant goods or
services used in connection with the energy, shipping, or shipbuilding
sectors of Iran, including NIOC, NITC, and IRISL);

iv. Section 1245(a)(1) of IFCA (with respect to non-U.S. persons who sell,
supply, or transfer to or from Iran precious metals or specified materials
(graphite, raw or semi-finished metals such as aluminum and steel, coal,
and software for integrating industrial processes), subject to certain
limitations as described in section VI below); and

v. Section 1246(a) of IFCA42 (for non-U.S. persons who provide
underwriting services, insurance, or reinsurance in connection with
activities involving Iran that are described in sections 17.1 to 17.2 and
17.5 of Annex V of the JCPOA, or to or for any individual or entity whose
property and interests in property are blocked solely pursuant to E.O.
13599).


b. Revoked: E.O. 13574, including section 1 (providing implementation authority for
certain menu-based sanctions under ISA); E.O. 13590, including section 1
(providing for menu-based sanctions with respect to persons who knowingly sell,
lease, or provide to Iran goods, services, technology, or support that could directly
and significantly contribute to the maintenance or expansion of Iran’s domestic
production of petrochemical products); E.O. 13622, including section 2(a)(i)-(iii),
as amended by section 16 of E.O. 13645 (for persons engaging in significant
transactions for the purchase, acquisition, sale, transport, or marketing of
petroleum, petroleum products, and petrochemical products from Iran and
successor entities of such non-U.S. persons); and section 5 of E.O. 13628
(providing for menu-based sanctions with respect to persons who knowingly,
between July 1, 2010, and August 10, 2012: sold, leased, or provided to Iran
goods, services, technology, information, or support that could directly and
significantly facilitate the maintenance or expansion of Iran’s domestic production
of refined petroleum products; sold or provided to Iran refined petroleum
products; or sold, leased, or provided to Iran goods, services, technology,
information, or support that could directly and significantly contribute to the
enhancement of Iran’s ability to import refined petroleum products).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of sanctions on the energy and petrochemical sectors:

As a result of the lifting of sanctions specified in sections 4.3.1 to 4.3.6 of Annex II and section
17.1 of Annex V of the JCPOA and described in this section, beginning on Implementation Day
such sanctions, including sanctions on associated services, do not apply to non-U.S. persons
who: (i) are part of the energy sector of Iran; (ii) purchase, acquire, sell, transport, or market
petroleum, petroleum products (including refined petroleum products), petrochemical products,
or natural gas (including liquefied natural gas) to or from Iran; (iii) provide to Iran support,
investment (including through joint ventures), goods, services (including financial services), and
technology that can be used in connection with Iran’s energy sector, the development of its
petroleum resources, and its domestic production of refined petroleum products and
petrochemical products; or (iv) engage in activities with Iran’s energy sector, including NIOC,
NITC, and NICO.


For additional information on the energy and petrochemical sector-related sanctions lifting
discussed in this subsection, please see section B of the
JCPOA FAQs.

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