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The EU Blocking Regulation adopted in 1996 prohibits EU persons to comply with extraterritorial laws that are explicitly listed. Following the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) in May 2018, the Commission put forward proposals to include certain US sanctions on Iran in the list attached to the Regulation. Whilst the Commission’s objective is to protect Iran-related business interests of EU companies and individuals, this initiative poses a lot of concerns for European banks.
In the EBF’s view, the guidance must state very clearly that the Regulation does not intend to prevent EU persons from adopting a risk-based approach towards their business dealings with Iran.