Iranian Sanctions - What Are The Facts?

This topic has been discussed so much on Oil Price, but most of the information has come from "news reports" that may or may not have merit.  The real information is at the U.S. Government's websites: U.S. Department of State - Iran SanctionsU.S. DEPARTMENT OF THE TREASURY - Iran Sanctions and also the Federal Register, Presidential Executive Order 13846 of August 6, 2018 - Reimposing Certain Sanctions With Respect to Iran

There may be more documents that relate to the sanctions since a number of U.S. Government agencies are involved.  If you find other information of interest, please bring it to the discussion.

Please review the documents above if you wish to find out the details but, to get the discussion going, here is what I understand to be the highlights from my perusal of the referenced documents:

The bit about paying (in India's case) in rupees, while certainly a topic being discussed these days, does not seem to relate to the U.S. Sanctions at all.  The sanctions that will be re-imposed* on November 4th are simply about buying oil from or participating in oil industry activities in or with Iran, not about dollars or any other currency.  Meaning if you buy oil from Iran or participate in any business related to its oil ports or oil infrastructure after November 4th, your financial assets or transactions in or passing through the United States will be more or less frozen or simply not accepted/revoked, any insurance underwriter that insures such cargos are also prohibited from participating and/or providing insurance, you will be subject to large $$ fines, and you are not even allowed to access or use electronic financial information from U.S. financial institutions you normally use.  I went to the U.S. State Department, the U.S. Treasury Department and the White House websites for a detailed review and it is complex, to say the least, but I believe the above are the key components.

In all sanctions-related legal documents (they are all laid out in detailed long-form legal format) the terms are strong and pretty unforgiving.  The possibility of waivers, while discussed, is meant to be extremely rare and only to be used while a country continues to wind down oil business with Iran.  Reasons given include a) the fact that every country has already been given at least 180 days to wind down such activities and to find alternate supplies, and b) the U.S. Government's target is to cut Iran's oil revenues to ZERO in order to bring them to the point of completely ceasing nuclear weapon development. 

I recently speculated that a country could possibly purchase their future oil supplies so long as they paid before November 4th; that is true to a limited extent as covered in the U.S. Government documents, but any country that wishes to do so must lay out a detailed need and a plan for the continued wind down of deliveries, usually within a few weeks or months.  In other words, you can't buy a year's worth of oil in advance.

*These sanctions were initially imposed BEFORE the Trump administration by the Obama administration, who also lifted them just prior to the end of his term when he signed the treaty that Trump later revoked.

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FAQ from U.S. Treasury Dept. government website:

Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the Joint Comprehensive Plan of Action (JCPOA)

Issued on May 8, 2018
Last Updated on August 6, 2018

This document is explanatory only and does not have the force of law. Please see particularly 
the legally binding provisions cited below governing the sanctions. This document does not 
supplement or modify the statutory authorities, Executive orders, or regulations.
 

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Iran Sanctions

Updated September 26, 2018
Congressional Research Service

Prepared for Members and Comittees of Congress

...This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. 

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12 minutes ago, Tom Kirkman said:

FAQ from U.S. Treasury Dept. government website:

Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the Joint Comprehensive Plan of Action (JCPOA)

Issued on May 8, 2018
Last Updated on August 6, 2018

This document is explanatory only and does not have the force of law. Please see particularly 
the legally binding provisions cited below governing the sanctions. This document does not 
supplement or modify the statutory authorities, Executive orders, or regulations.
 

That FAQ is a good one, although I believe it only applies to U.S. owned or controlled companies or U.S. citizens.  Is that how you interpreted it?

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Just now, Dan Warnick said:

That FAQ is a good one, although I believe it only applies to U.S. owned or controlled companies or U.S. citizens.  Is that how you interpreted it?

Yes.

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(edited)

4 minutes ago, Tom Kirkman said:

Iran Sanctions

Updated September 26, 2018
Congressional Research Service

Prepared for Members and Comittees of Congress

...This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan 
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and 
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other 
than public understanding of information that has been provided by CRS to Members of Congress in 
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not 
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. 

Whew!  That's longer than the long form sanctions themselves.  The CRS folks showed their relevancy with that one, eh?

Note to our non-U.S. friends:  Since Donald Trump challenged Barrack Obama's eligibility to be president based on where he was born, we take our short-forms and long-forms seriously.  Not really, but......

Edited by Dan Warnick

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Including this pdf for the huge amount of official / government links embedded in the document.

The Missile Sanctions Gap

About the Wisconsin Project

The Wisconsin Project on Nuclear Arms Control is a non-profit, non-partisan organization based in Washington D.C. that conducts research, advocacy, and public education designed to inhibit 
the spread of nuclear, chemical, and biological weapons and the missiles to deliver them. The organization was founded in 1986 by Gary Milhollin, in cooperation with the University of 
Wisconsin. 

The Wisconsin Project's mission is to reduce the risk that exports will accelerate the proliferation of weapons of mass destruction. The Project helps governments comply with the 
export restrictions in international agreements, and helps them ensure that their national controls on strategic goods are enforced. The Project also publicizes clandestine transactions in 
these goods, and draws attention to weaknesses in trade agreements and national laws. 

Through its research, testimony, and publications, the Project has influenced the export policies of major supplier countries.

 

About Iran Watch

Iran Watch is a website published by the Wisconsin Project that monitors Iran’s capability for building nuclear weapons and long-range missiles. The purpose of the website is to increase public awareness of the strategic situation in Iran and to make detailed knowledge of Iran’s weapon potential available to policymakers, the media, private scholars, and the general public. 
Through Iran Watch, the Wisconsin Project provides an objective resource for monitoring and assessing the implementation of the nuclear agreement, or Joint Comprehensive Plan of Action (JCPOA). The site contains thousands of primary source documents related to Iran, as well as 
reports on Iran's nuclear and missile programs, profiles of the entities involved in or supporting these programs, and analysis of the international effort to halt them.

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Sanctions legal notice from EU:

Financial Sanctions Notice

07/06/2018
Iran (Nuclear Proliferation)

Introduction
1. Council Regulation (EU) 267/2012 (“the Regulation”) imposing financial sanctions in relation to Iran (Nuclear Proliferation) has been amended.

2. Identifying information for the individuals and/or entities listed in the Annex to this Notice has been amended.

...

6. Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

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Website with UK Government sanctions against Iran.  Multiple documents available for download on this UK Gov site:

Financial sanctions, Iran (nuclear proliferation)

This page contains the list of asset freeze targets, listed because of proliferation-related activity in Iran. It also contains information on regulations.

...

Sanctions

Iran is currently subject to financial sanctions. UN and EU sanctions under the Iran (Nuclear Proliferation) sanctions regime are implemented in the UK through Council Regulation (EU) No 267/2012.

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25 minutes ago, Tom Kirkman said:

Sanctions legal notice from EU:

Financial Sanctions Notice

07/06/2018
Iran (Nuclear Proliferation)

Additional sanctions from EU, this one for Human Rights violations rather than for nuclear proliferation.

Financial Sanctions Notice

13/04/2018
Iran (Human Rights)

Introduction

1. Council Regulation (EU) 359/2011 (“the Regulation”) imposing financial sanctions against Iran (Human Rights) has been amended.

2. Identifying information for the individuals and entity listed in the Annex to this Notice has been amended.

...

6. Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

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49 minutes ago, Tom Kirkman said:

Including this pdf for the huge amount of official / government links embedded in the document.

The Missile Sanctions Gap

About the Wisconsin Project

The Wisconsin Project on Nuclear Arms Control is a non-profit, non-partisan organization based in Washington D.C. that conducts research, advocacy, and public education designed to inhibit 
the spread of nuclear, chemical, and biological weapons and the missiles to deliver them. The organization was founded in 1986 by Gary Milhollin, in cooperation with the University of 
Wisconsin. 

The Wisconsin Project's mission is to reduce the risk that exports will accelerate the proliferation of weapons of mass destruction. The Project helps governments comply with the 
export restrictions in international agreements, and helps them ensure that their national controls on strategic goods are enforced. The Project also publicizes clandestine transactions in 
these goods, and draws attention to weaknesses in trade agreements and national laws. 

Through its research, testimony, and publications, the Project has influenced the export policies of major supplier countries.

 

About Iran Watch

Iran Watch is a website published by the Wisconsin Project that monitors Iran’s capability for building nuclear weapons and long-range missiles. The purpose of the website is to increase public awareness of the strategic situation in Iran and to make detailed knowledge of Iran’s weapon potential available to policymakers, the media, private scholars, and the general public. 
Through Iran Watch, the Wisconsin Project provides an objective resource for monitoring and assessing the implementation of the nuclear agreement, or Joint Comprehensive Plan of Action (JCPOA). The site contains thousands of primary source documents related to Iran, as well as 
reports on Iran's nuclear and missile programs, profiles of the entities involved in or supporting these programs, and analysis of the international effort to halt them.

Excellent resource, and one I was hoping would surface when starting this discussion.  Helps with the bottom line question:  Do you want Iran to have nuclear weapons with the capability to deliver warheads to your country?  I don't.

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1 hour ago, Tom Kirkman said:

Sanctions legal notice from EU:

Financial Sanctions Notice

07/06/2018
Iran (Nuclear Proliferation)

Introduction
1. Council Regulation (EU) 267/2012 (“the Regulation”) imposing financial sanctions in relation to Iran (Nuclear Proliferation) has been amended.

2. Identifying information for the individuals and/or entities listed in the Annex to this Notice has been amended.

...

6. Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

So it appears that the only thing that the U.S. and the EU disagree on is the linking of nuclear weapons and missiles, and of course the enforcement aspect.  The document above shows they have enforcement actions in place, but the other reports indicate a complete lack of enforcement.  Not acceptable.

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Gosh, All this is so complicated. Politics is not my cup of tea. I'm sure you know better. So, anyone here who can tell if there is any country in the world that actually used nuclear weapon in a war situation?

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1 hour ago, NAPHTA said:

Gosh, All this is so complicated. Politics is not my cup of tea. I'm sure you know better. So, anyone here who can tell if there is any country in the world that actually used nuclear weapon in a war situation?

Switzerland.  Only Switzerland.

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Should have thought of it. Ruthless, self-centred Swiss with their big bankers in Geneva!

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SWISS keep getting worse as time goes by. I mean if your best buddy and  ally is the saw loving MBS, you can only keep sinking!

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30 minutes ago, St. Pedro said:

SWISS keep getting worse as time goes by. I mean if your best buddy and  ally is the saw loving MBS, you can only keep sinking!

Suisse bashing? LOL

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1 hour ago, ceo_energemsier said:

Suisse bashing? LOL

Switzerland had a secret nuclear program from 1948 to 1988

https://www.globalsecurity.org/wmd/world/switzerland/nuke.htm

and it's the only country in the world where the whole population can be protected in nuclear shelters.  During  the Cold War a law was adopted: a nuclear shelter was mandatory for every new house built in the country.

https://www.swissinfo.ch/eng/business/always-be-prepared_how-ready-is-switzerland-for-a-nuclear-disaster-/43570374

So a post-apocalyptic world would be Swiss dominated !

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14 minutes ago, Guillaume Albasini said:

Switzerland had a secret nuclear program from 1948 to 1988

https://www.globalsecurity.org/wmd/world/switzerland/nuke.htm

and it's the only country in the world where the whole population can be protected in nuclear shelters.  During  the Cold War a law was adopted: a nuclear shelter was mandatory for every new house built in the country.

https://www.swissinfo.ch/eng/business/always-be-prepared_how-ready-is-switzerland-for-a-nuclear-disaster-/43570374

So a post-apocalyptic world would be Swiss dominated !

Great place to be ....

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Just now, ceo_energemsier said:

Great place to be ....

You got great chocolate, cheese, gold and CH , and watches, what more!!!!

I enjoy all my time in Suisse

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Going back to the main topic : US sanctions on Iran...

All those documents on the US sanctions are one thing... but the real question is how the US will enforce the sanctions ? It's easy to apply sanctions to a dozen of companies... but it won't be so easy to enforce sanctions if there are hundreds of companies still doing business with Iran.

Some years ago the it was Iran vs the rest of the world but this time is more US vs the rest of the world and that makes a difference.

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29 minutes ago, Guillaume Albasini said:

Going back to the main topic : US sanctions on Iran...

All those documents on the US sanctions are one thing... but the real question is how the US will enforce the sanctions ? It's easy to apply sanctions to a dozen of companies... but it won't be so easy to enforce sanctions if there are hundreds of companies still doing business with Iran.

Some years ago the it was Iran vs the rest of the world but this time is more US vs the rest of the world and that makes a difference.

The US have a good set up for financial enforcement as well as naval blockage

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A vessel carrying 2 million barrels of Iranian oil discharged the crude into a bonded storage tank at the port of Dalian in northeast China on Monday, according to Refinitiv Eikon data and a shipping agent with knowledge of the matter.

Iran, the third-largest producer in the Organization of Petroleum Exporting Countries (OPEC), is finding fewer takers for its crude ahead of U.S. sanctions on its oil exports that will go into effect on Nov. 4. The country previously held oil in storage at Dalian during the last round of sanctions in 2014 that was later sold to buyers in South Korea and India.

The very large crude carrier Dune, operated by National Iranian Tanker Co, offloaded oil into a bonded storage site at the Xingang section of the port, according to a shipping source based in Dalian, adding this was the first Iranian oil to discharge into bonded storage in nearly four years.

The tanker left the Iranian oil port at Kharg Island on Sept. 12, according to ship-tracking data.

The Xingang area is home to several tank farms including commercial and strategic reserves. China National Petroleum Corp (CNPC) and Dalian Port PDA Co Ltd both operate commercial storage in the area, according to information on their company websites.

An investor relations official at Dalian Port declined to comment.

A manager at the bonded crude storage site operated by Dalian Port declined to comment whether Iranian oil were moved to the tanks, calling it the “worst time” to give any comment regarding Iranian crude because of the U.S. sanctions.

A person at the CNPC-owned storage site who refused to identify himself when contacted by Reuters said it is “impossible” that the oil is stored there.

A spokesman for CNPC said he had no information on this matter.

An executive with the China office of National Iranian Oil Co (NIOC) declined to comment. NIOC also did not respond to an email request seeking comment if it is storing oil at Dalian.

The shipping source said there is no buyer earmarked for the cargo.

Three other NITC tankers are set to arrive in Dalian in the next week or two, the ship-tracking data shows. Some of those cargoes are also likely to end up in bonded storage as the refineries in the region, controlled by CNPC, are not equipped to process Iranian oil, said three sources at state-run Chinese refiners.

China’s Iranian oil buyers, including state-owned refiner Sinopec and state trader Zhuhai Zhenrong Corp, have shifted their cargoes to vessels owned by NITC since July to keep supplies flowing as the U.S. sanctions have been re-imposed.

Keeping oil in bonded storage gives the shipment owner the option to sell into China or to other buyers in the region.

In early 2014, NIOC leased bonded tanks in Dalian and oil from there was shipped to South Korea and India, Reuters reported.
Source: Reuters (Reporting by Chen Aizhu and Meng Meng; Additional reporting by Beijing newsroom; Editing by Christian Schmollinger)

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