Division 6 ‘ Iran Threat Reduction and Syria Human Rights Act of 2012 ’F1

Required compliance:

• Not to knowingly:

  1. (i)

     provide underwriting services, insurance or reinsurance to certain Iranian persons;

  2. (ii)

     facilitate the issuance of Iranian sovereign debt, or of debt of entities controlled by the latter;

  3. (iii)

     engage in any transaction directly or indirectly with the Government of Iran or any person subject to the jurisdiction of the Government of Iran prohibited by US law (applies to foreign subsidiaries owned or controlled by US persons);

  4. (iv)

     provide specialized financial messaging services to, or enable or facilitate direct or indirect access to such messaging services for the Central Bank of Iran or a financial institution whose interests in property are blocked in connection to Iran's proliferation activities.

  With regard to (i), there are exceptions for humanitarian assistance, food and medical products supply, and depending on the level of due diligence applied.

• Possible damages to F2United Kingdom interests:

  Measures to limit imports into USA or procurement to USA, prohibition of designation as primary dealer or as repository of US Government funds, denial of access to loans from US financial institutions or transfers through such institutions, prohibition of transactions in foreign exchange subject to the jurisdiction of the USA, export restrictions by USA, prohibition of property transactions subject to the jurisdiction of the USA, or refusal of assistance by EXIM-Bank, prohibitions and limitations to the opening and maintenance of correspondent accounts in the USA