Lifting Of Previously Suspended Sanctions Against Iran

Author:Dr. Markus Schott and Andrew M. Garbarski
Profession:Bär & Karrer

On 12 August 2015, the Swiss Federal Council decided to lift certain sanctions against Iran that had been temporarily suspended since 30 January 2014. The amendments to the Ordinance on Measures regarding the Islamic Republic of Iran (the "Ordinance") came into effect on 13 August 2015.

The amendments lift the requirement to report trade in Iranian petrochemical products. Furthermore, the requirement to report the transport of Iranian crude oil and petroleum products, as well as insurance and reinsurance policies taken out in relation to such transactions, is lifted. The amendments also lift the ban on precious metals transactions with Iranian state bodies. In the financial sector, threshold values for reporting and licensing obligations in relation to money transfers from and to Iranian nationals are increased. Finally, the amendment introduces a general exemption clause.

The decision of the Swiss Federal Council underlines its support for the implementation of the Joint Comprehensive Plan of Action (JCPOA) reached by the E3/EU+3 (China, France, Germany, Russia, UK and USA, with the High Representative of the European Union for Foreign Affairs and Security Policy) and Iran on 14 July 2015, as well as Switzerland's interest in deepening its bilateral relations with Iran.

The present briefing aims to provide an overview of the amendments to the Ordinance on Measures regarding the Islamic Republic of Iran in the context of the ongoing international process to resolve the nuclear dispute.


On 14 July 2015, the E3/EU+3 and the Islamic Republic of Iran adopted the JCPOA that provides for a comprehensive range of measures to be taken by Iran to limit and control its nuclear program and roll back UN Security Council sanctions as well as multilateral and national sanctions related to Iran's nuclear program, including steps on access in areas of trade, technology, finance, and energy. The JCPOA shall ensure that Iran's nuclear program will be exclusively peaceful. The JCPOA lays the foundation for a complete settlement of the nuclear dispute.

The UN Security Council has endorsed the JCPOA by unanimously adopting Resolution 2231 on 20 July 2015, calling upon all UN Member States, regional and international organizations to support the implementation of the JCPOA.

Following the Security Council's adoption of Resolution 2231, the EU has amended its sanctions regime on Iran (cf. Council Regulation (EU) 2015/1327 of 31 July 2015 amending...

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