Extent of proposed US sanctions...25 Jul 2018 06:46
http://www.icj-cij.org/files/case-related/175/175-20180716-REQ-01-00-EN.pdf
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15. Before 6 August 2018, the USA will fully re-impose and enforce sanctions relating to the following sectors and activities:
- the purchase or acquisition of US dollar banknotes by the Government of Iran;
- direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi- finished metals such as aluminium and steel, coal, and software for integrating industrial processes;
- significant transactions related to the purchase or sale of Iranian Rial, or the maintenance of significant funds or accounts outside the territory of Iran denominated in the Iranian Rial;
- the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and
- activities related to Iran’s automotive sector.
16. Before 4 November 2018, the USA will fully re-impose and enforce sanctions relating to the following sectors and activities:
- Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (“IRISL”), South Shipping Line Iran, or their affiliates;
- petroleum-related transactions with, among others, the National Iranian Oil Company (NIOC), Naftiran Intertrade Company (“NICO”), and National Iranian
21 Executive Order 13716, 16 January 2016, 81 FR 3693. 22 See point 2.2 of the OFAC Re-imposition FAQ.
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Tanker Company (“NITC”), including the purchase of petroleum, petroleum products, or petrochemical products from Iran;
- transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions;
- the provision of specialised financial messaging services to the Central Bank of Iran and Iranian financial institutions;
- the provision of underwriting services, insurance, or reinsurance; and
- Iran’s energy sector.
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IMHO our proposed services/contract would breach any of these?