The United Nations (Sanctions – Iran) Regulations 2014 (“Sanctions“) was enacted and took effect on 29 September 2014. The United Nations (Sanctions – Iran) Regulations 2007 (“2007 Sanctions“) have been correspondingly revoked. The Sanctions build on the existing sanctions detailed in the 2007 Sanctions and provide for additional prohibitions and duties pursuant to United Nations Security Council (UNSC) Resolutions 1747 (2007), 1803 (2008), and 1929 (2010) (“Resolutions“). The Sanctions also accord wider powers to the authorities to manage vessels and property which are suspected of contravening the respective resolutions. Do note that financial institutions regulated by the Monetary Authority of Singapore are not subject to the Sanctions but are instead subject to similar prohibitions enacted under the Monetary Authority of Singapore (Sanctions and Freezing of Assets of Persons – Iran) Regulations 2007. New Prohibitions The Sanctions set out several new prohibitions, including:

  • Prohibition against selling or making available interest in certain commercial activities;
  • Prohibition against transfer of technology or technical assistance relating to ballistic missiles;
  • Prohibition against provision of bunkering services; and
  • Prohibition against provision of financial services and other resources.

In general, the above prohibitions are in line with the Resolutions, which seek to, amongst others, reduce the supply, sale, or transfer of major military weapons systems, related materials, technology, and financial assistance aimed at military purposes to Iran, as well as target any possible external support for Iran’s suspected development of nuclear weapons. The Sanctions also impose a general duty to exercise vigilance when doing business with any Iran-related individual or entity and set out the specific steps an individual should take to discharge this general duty. Broader Enforcement Powers Apart from the additional prohibitions, the Sanctions also expand on the overall ambit of the 2007 Sanctions with the inclusion of a forfeiture clause. The forfeiture clause gives the Singapore courts power, on the application of the Attorney-General, to order the forfeiture and subsequent destruction of suspected property. In the event there are reasonable grounds to believe that the cargo of a Singapore ship on the high seas includes any designated item in contravention of the regulations, the Director of Marine has the authority to authorize the inspection of such ship or direct the ship to proceed to an appropriate and convenient port for inspection. Conclusion The implementation of the Sanctions reflects Singapore’s stance in respect of its sanctions regime. As a member of United Nations, Singapore has been diligent in ensuring that it complies with the UN Security Council Resolutions. The prohibitions are therefore not unique to Singapore. Further, when considering the Sanctions, companies should note that the prohibitions cover not only persons in Singapore but also citizens of Singapore who are outside of Singapore. By Eugene Lim and Ken Chia

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