UK Iranian Trade News

Trading with Iran - Are Your Goods Sanctioned?

Products and Services

Members who are uncertain as to whether their products and services may still be sanctioned even though most EU/UK sanctions have been lifted should make contact with the Export Control Organisation (ECO) of the Department of International Trade :

ECO Helpline 020 7215 4594 and eco.help@trade.gsi.gov.uk.

Compliance

For general queries about the remaining measures, obtaining licences, and compliance issues - Members should go to the Office of Financial Sanctions Implementation (OFSI), which is part of HM Treasury.

For OFSI, the website is at: https://www.gov.uk/government/organisations/office-of-financial-sanctions-implementation

OFSI's email address is: OFSI@hmtreasury.gsi.gov.uk and their helpline is 020 7270 5454 (9-5 Mon-Fri).

General Background Information

Sanctions information about Iran is at https://www.gov.uk/guidance/sanctions-on-iran and for information about export controls members can go to https://www.gov.uk/government/organisations/export-control-organisation.

There is a 'Doing Business with Iran' guide at https://www.gov.uk/government/publications/doing-business-with-iran.


Banking Matters

As at the end of October 2016, banking services for Iran trade transactions are not generally available in the UK. They are more so, but still limited in other EU countries and around the world. Some UK banks will undertake Iran business, others won’t and would rather close the customer’s account than do so. The banks that will, do so, confidentially, for their best long-term customers, usually transaction by transaction not on a treaty basis. This means that the banking system doesn’t generally provide Iran trade finance services.

Those banks that won’t provide banking services for trade with Iran also do what they can to inhibit the rest of the market from doing so, by implying that they would withdraw clearing or correspondent banking.

This leaves "unbanked" exporters for Iran to construct specific payment routes. These involve using the buyer suggested payment arrangements, if necessary, in combination with banks which will undertake banking services for Iran trade (usually the correspondents of Iranian banks, EIH and others) so that the UK exporter’s payments are unknown to their UK bank. This involves risk to the exporter, of course. This may be happening as UK exports increased by about 30% in the first 6 months of 2016 by comparison with the similar period for the year before. This payment procedure happened under sanctions for allowable exports.

Something similar happens in Germany, Italy and other EU countries. Germany has a large number of small regional banks, many of whom are willing to provide payment services for Iran. These smaller banks are not constrained by the ability of the big German banks to hold the market to their own management policies on Iran. The Iranian banks in London could provide a route through this, if they weren’t hamstrung by clearing and correspondent relationships in the UK.

The term of the market doesn’t go beyond 360 days at present, although Iran is beginning to call for longer term credit.


New OFAC Guidance on US dollar transactions and Due Diligence.

New OFAC guidance on dollar transactions is that, Foreign Financial Institutions (FFIs), including the foreign incorporated subsidiaries of US financial institutions, may process US dollars payments or maintain US dollar denominated accounts involving Iran so long as they do not involve directly the US financial system or US persons FFIs could potentially comply with these requirements through the use of foreign reserves held outside the US or by keeping US dollar transactions ”on the books” without processing them through the US financial system. This sounds like a Euro-dollar which can only be used as an off-set for other US dollar transactions. It may not transit the US financial system, so for the vast majority trade transactions it won’t be useful.

It is now not necessarily sanctionable for a non-US person to engage in transaction with an entity that is not on the SDN List, but is minority owned, or controlled in whole or in part by an Iranian or Iranian related person on the SDN list. Apparently (source: Willkie Farr & Gallagher LLP) OFAC has also given informal Guidance that it is not necessarily sanctionable for non-US persons to engage in transactions with an entity that is 50% or more owned by an Iranian or related person on the SDN list.

This is a helpful clarification of OFAC guidance.


Bank Saderat.

Bank Saderat has been delisted since 22nd October 2016 as the result of an EU regulation in April 2016 which stipulated that sanctions would remain until that date.


Latest Iran Customs Statistics

According to Iran Customs published statistics from 20th March 2016 to 20th October 2016, Iran has:

  • EXPORTED NON OIL GOODS US$24.60 billion (5% more than last year in the same period)
  • IMPORTED US$24.00 billion (Similar to the last year same period)

The big changes is reduction importing from Asian countries and increase import from European countries. Although still the main exporter to Iran are China, UAE and Turkey.

Import from following countries have reduced

  • China 5.5% reduction
  • UAE 13 % reduction
  • South Korea 14% reduction
  • Turkey 13% reduction

In the same time import from Germany increased by 25% and from Europe by 17%