On July 26th, 2010, the Council of the European Union adopted a decision concerning restrictive measures against Iran (the Decision), which follows and exceeds the measures against Iran enacted by the United Nations on June 9th, 2010. It in some senses resembles and is designed to reinforce aspects of the United States Comprehensive Iran Sanctions, Accountability and Divestment Act of July 1st, 2010.
The Decision requests Member States (i.e., all the 27 countries of the European Union) to strengthen their vigilance on transportation and transit through the territory of each Member State and requires them to monitor the activities of financial institutions in their jurisdictions with Iran entities and related entities. The Decision also provides a list of entities and persons subject to freezing orders, to which no funds or economic resources shall be made available.
In addition, the Decision has significantly expanded the categories of activities subject to sanctions.
The recent USD298 million settlement reached between US agencies and Barclays highlights the risks faced by corporations and financial institutions flouting the sanctions regime and the commitment of certain governments in enforcing the sanctions.