farhad emam Farhad Emam
Publish Date : 01/22/2016

Lifting of the Sanctions on Iran as an End of the Beginning!


Key terms

SWIFT, SACE, Hermes Euler, Lloyds, oil tankers, Iranian banks.


Churchill once said: “Now this is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning.” The same phrase explains the Implementation Agreement between Iran and P5+1. Lifting of sanctions is not the end of the difficulties and the challenges that economy of Iran has been facing during the last 10 years. It cannot be considered as beginning of the end because serious challenges inside and outside Iran must be tackled before a glimmer of hope appears on the horizon. The Implementation Agreement, perhaps, is the end of the beginning because it heralds a new era in the politics and economic policy of Iran.

In this Legal Report three issues are briefly analyzed: 1) Iranian banks reconnected to SWIFT; 2) Lloyds to resume insuring Iranian oil tankers; and 3) Revival of State Guarantee for Exports to Iran.

Iranian banks reconnect to SWIFT: CBI

It is reported on the website of irna.ir on January 17, 2016 that:

The Central Bank of Iran (CBI) announced on Sunday that the Society for Worldwide Interbank Financial Telecommunication (SWIFT) has removed Iranian banks from its list of sanctioned financial institutions.

On the website of SWIFT, a more detailed explanation about the same subject is offered:

The EU has announced that the Implementing Legislation has taken effect. SWIFT has informed the relevant stakeholders about the necessary measures that need to be put in place to make it possible for those banks that are delisted by the Implementing Regulation to reconnect to SWIFT. As previously stated, those banks that are delisted by the Implementing Regulation will now automatically be able to reconnect to SWIFT, following the completion of our normal connection process (i.e. administrative and systems checks, connectivity and technical arrangements).

However, the “Update: Iran Sanctions Agreement” adds that:

The Implementing Regulation does not repeal all EU sanctions on all Iranian banks, therefore SWIFT remains prohibited from providing specialised financial messaging services to the EU-sanctioned Iranian banks that remain listed under EU Regulation.

Three Iranian banks, namely Bank Saderat, Mehr Eghtesad Bank, and Ansar Bank will remain subject to US Secondary sanctions because their names remain on the Specially Designated Nationals (SDN) list. The alleged reason is the affiliation of these banks to IRGC. According to the “Guidance relating to the lifting of certain US sanctions pursuant to the Joint Comprehensive Plan of Action on Implementation Day” published by the US Department of Treasury on January 16, 2016:

As of January 16, 2016, the following Iranian financial institutions are designated pursuant to E.O. 13224 and the GTSR or E.O. 13382 and the WMDPSR: Ansar Bank, Bank Saderat, Bank Saderat PLC, and Mehr Bank.

Lloyds to resume insuring Iranian oil tankers

It is reported on the website of irna.ir on January 18, 2016 that:

Iranian oil tankers use Lloyds insurance services from Monday, says Ali Akbar Safaei, Managing Director of the National Iranian Tanker Company, a few days after the removal of international sanctions against Iran.

According to the website of worldmaritimenews.com on January 19, 2016:

Lloyd’s Register told World Maritime News that they are able to provide classification services to Iranian controlled tonnage and that the society will be re-opening its office in Tehran.He said Iran's goal in contributing to establishment of refinery in Spain and other countries is guaranteeing lasting security of oil sales and exports.

However, it is added in the same report that:

On Monday, Mehr News Agency (MNA) reported that the society has lifted one of its sanctions against Iran thus allowing for the country’s oil tankers to enter the European Union’s oil ports and terminals. However, Lloyd’s Register could not confirm this to World Maritime News.

Classification, or class designation, according to Lloyd’s “Rules for Classification and Construction” comprises:

– the Character of Classification, i.e. a sequence of abbreviations indicating the extent of compliance with the applicable Rules and the duration of the Class period;

– Notations such as type and service Notations, additional Class Notations as well as range of navigation Notations affixed to the Character of Classification, indicating particular features capability, service restrictions or special equipment and installations, which are included in the Classification.

The following paragraph from the report prepared by Matthew Moran and Daniel Salisbury on “Sanction and the Insurance Industry, Challenges and Opportunities” explains the impact of halt in providing Iranian shipping companies with classification services:

Sanctions also have important implications in terms of their effect on classification societies. These are organisations which maintain standards on safety and the maintenance of ships, and work to verify these standards on board individual vessels around the world. A valid classification is typically required by a ship to enter ports around the world. Sanctions and related concerns regarding potential reputational risks have prompted these societies to halt their business in Iran. The EU has since imposed a specific prohibition on the provision of classification and other similar services to, in broad terms, Iranian oil tankers and cargo vessels.

Revival of State Guarantee for Exports to Iran

It is reported on the website of reuters.com on January 18, 2016 that:

Germany plans to revive state export guarantees for companies that want to do business with Iran following the lifting of international sanctions against the Islamic Republic, the Economy Ministry said on Monday.

The above good news comes with a “though”:

A spokesman for Economy Minister Sigmar Gabriel said export guarantees were now permitted again though some other issues had to be settled first such as payment of outstanding liabilities.

Does the above sentence mean that Iran-related insurance policies provided by Hermes carry outstanding liabilities of roughly 5 billion Euros? If this is true, then it is easy to understand the meaning of the following news reported by irna.ir on December 27, 2015:

The German Euler Hermes credit institution has agreed to establish a $5 billion credit line for Iran, Mohammad Khazai deputy minister of economy said Saturday. The credit is to be granted over 2-3 years.

SACE also signed an MOU with three Iranian banks (mehrnews.com, December 6, 2015):

Signing a Memorandum of Understanding (MoU) Iran's Pasargad private bank and Italy’s SACE group (Servizi Assicurativi del Commercio Estero) will jointly provide insurance services for traders of the two countries, said Mostafa Beheshtirouy, a member of Passagad’s board of directors, on Saturday in Tehran.

SACE reported on its website on November 30, 2015 that:

SACE and the banks intend to initiate a collaboration, consistent with applicable regulations and the restoration of the payments system, to identify short- and medium/long- term projects of mutual interest and to develop the insurance-financial structures best suited to support them.


To learn more about the issues mentioned in this Legal Report, you may read the following texts. If after reading this Legal Report and the following texts, you still have questions that call for detailed responses, you may send them to us by clicking on “Our Services” button and following the procedure explained there.


1. Law in Iran Legal News: Iranian banks reconnect to SWIFT: CBI, Friday, January 22, 2016.

2. Law in Iran Legal News: Lloyds to resume insuring Iranian oil tankers, Friday, January 22, 2016.

3. Law in Iran Legal News: Revival of State Guarantee for Exports to Iran, Friday, January 22, 2016.

4. Law in Iran Legal News: Sace Signs Agreements with Iranian Private Banks, Friday, January 1, 2016.


1. Law in Iran Legal Report No. 6: International Banking Operations in Iran, Sunday, September 6, 2015.

2. Law in Iran Legal Report No. 16: International Banking Partnership of Iran and India, Friday, January 1, 2016.


Law in Iran Booklet No. 6: International Banking in Iran, Sunday, September 6, 2015.


Farhad Emam, International Banking Laws and Regulations (Chapter on Iran), OCEANA, 2000.


All rights reserved for Mr. Farhad Emam. No part of these pages, either text or image may be used for any purpose other than personal use. Therefore, reproduction, modification, storage in a retrieval system or retransmission, in any form or by any means, electronic, mechanical or otherwise, for reasons other than personal use, is strictly prohibited without his prior written permission and shall have legal consequences.