The United Nations, the European Union, the United States and other jurisdictions administer a range of economic sanctions designed to further their foreign policy goals. Such sanctions include broad comprehensive embargoes on a number of countries and regions, as well as more targeted restrictive measures against certain listed persons and entities (“Sanctioned Persons”). While the United States currently imposes a comprehensive embargo on Iran, sanctions administered by the EU and UN do not seek to prevent all trade or business with Iran, but rather, only business that involves Sanctioned Persons or transactions involving arms, missile technology, nuclear-related transfers and activities, as well as certain telecommunication monitoring equipment.
International Sanctions
The Joint Comprehensive Plan of Action
On 23 November 2013, China, France, Russia, the United Kingdom, the United States and Germany (the so called “P5+1”) the European Union and Iran reached an interim agreement, known as the Joint Plan of Action, regarding the Iranian nuclear program. Under this agreement, in return for Iran taking several steps…
EU Sanctions
EU sanctions apply to EU nationals wherever located, to any legal entity incorporated under the law of an EU Member State, to any person located in the territory of an EU Member State and to any business activities carried out in whole or part in an EU Member State. The…
US Sanctions
US sanctions can be divided into primary sanctions and secondary sanctions. US primary sanctions apply to “US persons” (including US citizens and permanent residents, companies organised in the US and any persons located in the US) or activities that involve a US nexus. US secondary sanctions are applicable to non-US…
Pomegranate’s compliance with sanctions
The Company believes that its activities have at all times been conducted in full compliance with all applicable sanctions. Sanctions compliance strategy The Company adopted a Sanctions Compliance Strategy on 26 June 2014 setting out the fundamental position of the Board of Directors that the Company shall strive to observe…