New year, new round of sanctions for Iran

Until so far, 2020 has not been a good year for Iran. The new decade is only a couple of weeks away, and Iran has been confronted with the killing of one of its top generals – Qasem Soleimani – by the United States (“US“), the accidental shooting down of an Ukrainian airliner, a new round of sanctions by the US, and the triggering of the dispute resolution mechanism in the Joint Comprehensive Plan of Action (“JCPOA“) by the United Kingdom (“UK“), France and Germany.

New US sanctions: Iranian metals industry

On 3 January 2020, a US drone strike near the international airport of Baghdad led to the death of Soleimani. Several days later, Iran responded and launched ballistic missiles at two US military bases in Iraq. On 10 January 2020 the Office of Foreign Assets Control (“OFAC“) of the US Department of the Treasury targeted Iran’s billion-dollar metals industry and senior regime officials with new sanctions. OFAC sanctioned:

  • foreign purchasers and transporters of Iranian steel, and providers of critical materials needed for Iranian metal production;
  • Iranian aluminium and copper companies;
  • eight senior Iranian regime officials

The eight senior Iranian officials who were sanctioned on 10 January have been designated under E.O. 13876 in response to their alleged involvement in the ballistic missile strikes on these two US military bases. One of the implications of the sanctions is, that all property and interests in property of these persons that are in the US or in the possession or control of US persons must be blocked and reported to OFAC. More information regarding the sanctions, can be found here: link.

Iran/Ukraine jet incident

On 8 January 2020, a commercial airliner, bound for Ukraine, was shot down shortly after takeoff from Tehran Imam Khomeini International Airport, by the Iranian army. All 176 passengers and crew were killed. The president of Iran, Rouhani, later described the accident as an “unforgivable mistake”. US Treasury Secretary Steven Mnuchin said the US will issue waivers from Iran sanctions to facilitate the investigation into the shooting down of the plan.

UK, France and Germany trigger JCPOA dispute resolution mechanism

On 6 January 2020, Iran announced that it will no longer observe its commitments under the 2015 nuclear deal, following the US killing of Suleimani. Iran has not withdrawn from the JCPOA, but does not commit anymore to its limitations on the number of centrifuges and enrichment of uranium. On 14 January 2020, the UK, France and Germany, released a joint statement regarding the triggering of the dispute resolution mechanism included in the JCPOA. According to the statement the decision was taken because Iran announced that it would no longer observe its commitments following from JCPOA. The statement also confirms that the three European countries are committed to preserve the deal and bring Iran back to full compliance.

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