Regulation (EU) No 267/2012 (Iran restrictive measures)
The March 23, 2012 regulation carrying EU sanctions against Iran's nuclear program, largely lifted on January 16, 2016 and restored in its sectoral measures on September 29, 2025.
Council Regulation (EU) No 267/2012 of March 23, 2012 gathers the EU's restrictive measures against Iran over its nuclear program. It implements Security Council resolutions and adds autonomous measures. These include the oil embargo decided on January 23, 2012, the ban on financing, insuring and reinsuring the transport of Iranian crude, petroleum products and petrochemicals, and the ban on insuring and reinsuring the Iranian state and Iranian legal persons. For an insurer, it is one of the few texts that name its trade outright. Under the Joint Comprehensive Plan of Action (JCPOA), Regulation (EU) 2015/1861 lifted most of it on Implementation Day, January 16, 2016: oil, gas, petrochemicals, banking, insurance and shipping, with hundreds of persons delisted. After UN sanctions returned, the Council adopted Regulations 2025/1975, 2025/1980 and 2025/1982 on September 29, 2025. Back came the ban on importing, purchasing and transporting Iranian crude, petroleum products, natural gas and petrochemicals, with the related financing and insurance services, and the ban on exporting key oil, gas and petrochemical equipment. Also back came the ban on trade in gold, precious metals and diamonds, restrictions on naval equipment, graphite, certain metals and software, the ban on insuring Iranian legal persons and asset freezes on more than fifty individuals and close to two hundred entities, banks and shipowners included. The reinstatement does not apply retroactively to contracts concluded before September 30, 2025 and consistent with the JCPOA, but a policy can be neither extended nor renewed. A cargo book touching the Persian Gulf is therefore reread bill of lading by bill of lading, against the annexes.
Textbook case: a European reinsurer writes a 25 percent quota share of the cargo book of a South Asian cedant, which covers among other things polyethylene shipments. Over the year, 3 percent of the EUR 40,000,000 of insured values involves polyethylene of Iranian origin: 40,000,000 x 3% = EUR 1,200,000, of which 1,200,000 x 25% = EUR 300,000 falls in the reinsurer's share. From September 30, 2025, reinsuring those voyages falls under the restored ban. At renewal, the treaty cannot take that flow back; the treaty's sanctions exclusion clause carves it out, and the cedant must be able to identify the goods' origin on its bordereaux.
Regulation 267/2012, EU Iran regulation, Iranian oil embargo, EU Iran sanctions, Article 35 insurance ban, Regulation 2025/1975, Regulation 2015/1861
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