There’s No Getting Around Iranian Sanctions

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By Irina Slav, a writer for the U.S.-based Divergente LLC consulting firm with over a decade of experience writing on the oil and gas industry. Originally published at OilPrice

“I personally think none of us will be able to get around it,” Vitol’s chief executive Ian Taylor said last week, commenting on the effects that renewed U.S. sanctions against Iran will have on the oil industry.

The sanctions, to go into effect later in the year, have already started to bite. French Total, for one, announced earlier this month it will suspend all work on the South Pars gas field unless it receives a waiver from the U.S. Treasury Department—something rather unlikely to happen. The French company has a lot of business in the United States and cannot afford to lose its access to the U.S. financial system. So, unless the EU strikes back at Washington and somehow manages to snag a waiver for its largest oil company, Total will be pulling out of Iran.

Other supermajors have not dared enter the country, so there will be no other pullouts of producers, but related industries will be affected, too, in the absence of a strong EU reaction to the sanctions. For example, Boeing and Airbus will both have their licenses for doing business in Iran revoked, Treasury Secretary Steven Mnuchin said, which will cost them some US$40 billion—the combined value of contracts that the two aircraft makers had won in Iran.

Tanker owners are also taking the cautious approach. They are watching the situation closely, anticipating Europe’s move, but acknowledging that the reinstatement could have “significant ramifications” for the maritime transport industry, as per the International Group of PI & Clubs, which insures 90 percent of the global tanker fleet.

Everyone is waiting for Europe to make its move even as European companies in Iran are beginning to prepare their exit from the country. Everyone remembers the previous sanctions, apparently, and they don’t want to be caught off guard. But the signals from Europe are for now positive for these companies, of which there are more than a hundred.

Earlier this month, an adviser to French President Emmanuel Macron saidthat Europe’s response to the thread of U.S. sanctions on Iran will be “an important test of sovereignty.” Indeed, unlike the last time there were sanctions against Iran, the European Union did all it could to save the nuclear deal and has signaled it will continue to uphold it.

While some doubt there is a lot the EU can do against U.S. sanctions, there is one 1996 law dubbed a blocking statute that will ban European companies from complying with U.S. sanctions, which would put companies such as Total between a rock and a hard place.

European Commission President Jean-Claude Juncker said two weeks ago the commission will amend the statute to include the U.S. sanctions again Iran and that the amendments should be completed before the first round of sanctions kicks in in early August.

Many observers believe that if the sanctions are only limited to the U.S. and no other signatory to the nuclear deal joins them, the effect will be limited as well. As McKinsey analyst Elif Kutsal told Rigzone, “Market fundamentals are not expected to change structurally given that Iran doesn’t export crude oil or refined products to the U.S. and exports go mainly to Europe (20 percent) and Asia Pacific (80 percent). Therefore, if the sanctions are only limited to the United States, then this could cause short-term volatility in prices until a new/revised agreement framework is put in place.”

And this is where Iran’s Supreme Leader Ayatollah Ali Khamenei scored a goal: He demanded that the European Union provide guarantees it will continue to buy Iranian crude. If it doesn’t, he said, Iran will restart its nuclear program. Now, if this happens, the EU will not have much choice but to join the sanctions, and then hundreds of thousands of barrels of Iranian crude could be cut off from global markets.

However, even this will result in only a temporary decline in supplies, according to Kutsal, and others that believe that Asian imports from Iran will offset the effect from the U.S. sanctions. According to this camp, the only thing that can unleash the full effect of sanctions is the UN joining the sanction push against Iran.

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  1. Oregoncharles

    “related industries will be affected, too, in the absence of a strong EU reaction to the sanctions.”

    And what would that be? The “blocking statute” doesn’t sound like it will help much. Isn’t what’s really needed a clearing system that doesn’t depend on the Federal Reserve? Could the ECB provide the same service for transactions in Euros? Apparently Russia and China are working on something similar.

    Or would that provoke a US invasion?

    1. nervos belli

      The FED has no transaction system. SWIFT has. SWIFT is nominally headquartered in Belgium, however the US obviously has a strong influence, probably stronger.

      Doing monetary transactions are not a problem in any way. The problem is: EU corporation does business with Iran. US doesn’t like that and prohibits corporation to do any business with US companies or in the US market. Instant death penalty for this corporation. As happened with ZTE recently who sold phones to Iran when there were still sanctions. The US forbade to sell ZTE anything in the US as a punishment.

      1. Clive

        SWIFT is in effect owned by the banks which subscribe to the SWIFT service. So SWIFT itself is a bit of a red herring. Ultimately it’s the banks who are liable for adherence to (or ignoring of) a sanctions regime.

        Which goes back to the basic premise of the article. Any bank which (say for the sake of argument) transacts with Iran via SWIFT would be liable to have the US cut off their access to US dollar clearing. While not necessarily a fatal blow, they’d have to operate via a correspondent bank which retained that access — a big operating impediment with cost and efficiency implications.

        They’d also have a risk that the correspondent bank could come under US pressure to yank that facility out from under them.

        The US has been unstinting in taking a very hard line on this subject e.g. and and —- it has very little to lose and an awful lot to gain (in terms of geopolitical willy-waving and generally being able to demonstrate how it can throw its weight around).

        1. vlade

          What I’d be interested in knowing is whether EU could reciprocaly cut US banks off SWIFT given SWIFT is Belgian. Iran/Russia/China could deal with EU in EURos, to avoid USD clearing issues.

          Of course, that would be a massive economic war, but given how roughshod US was running over EU (not just Trump, but US in general), I suspect it’s only matter of time anyways.

          It may not do that much to the US economy in general (in fact, over the long term decreased reliance on USD could help there, although it would weaken US political clout), but it would likely put a lot of hurt on the large US banks.

          1. Clive

            No, not in and of itself. It’s one of those questions where the EU is perceived to be a state-level actor (it doesn’t always go out of its way to dispel such misconceptions) but is largely dependent on the “real” nation states to implement its Directives (compelled, as they are, by Treaty or Treaties).

            For banks, Member States are deemed to have competence.

            A new Directive could in theory be issued to the effect you describe. But that is a years-long process with as you rightly say no shortage of geopolitical fall-out. It would never have seen the light of day pre-Brexit. Now, that’s been reduced to an outside outside possibility. I would not, now, though, say it was a complete impossibly.

          2. PlutoniumKun

            My guess is that if the EU starts to take retaliatory action it wouldn’t be on the banking system (too much potential blowback), but on the internet giants. Cracking down harder on FB, Google etc., under the guise of protecting consumer information would be both popular in the EU and would be a powerful way of putting pressure back on the US.

          3. RBHoughton

            SWIFT is still Belgian? Was it not rather forcibly transferred to Wells Fargo a few years back?

  2. Tomonthebeach

    Of course, this gloomy forecast suffers from the missing variables in the equation problem. Oil and gas rigs are sprouting up all over the Mediterranean lately, and that will reduce dependencies on imports.

    There is the slim possibility that EU will go to financial war with the USA. If I were Tusk, I would be pushing for that. It is well past time that EU reduced the ability of the US to meddle in its affairs, especially since we Americans are clearly going through a self-destructive phase ourselves.

    1. PlutoniumKun

      Europe is, and will remain almost entirely dependent on middle eastern oil – most of those discoveries are gas, and Iran is not a major gas exporter. The problem is infrastructure – gas requires massively expensive pipelines and LNG terminals – they take years and billions to build. And oil is not as fungible a product as often assumed, refineries are built to take certain grades. Iranian oil is generally heavy and sour, in contrast to the light sweet crudes from the rest of the Middle East.

      So far as I know, Japan is the major export market for Iran, as well as China. The main problem for Europe is not so much the loss of Iranian supplies, but the knock-on effect through the entire supply system. If Japan can’t get Iranian crude, they need to buy off someone else, and this raises prices for everyone.

      But having said that, the main European interest in Iran is not directly buying their oil – its selling the things Iran needs with its hard currencies. Europe knows that if it doesn’t get those contracts, China and Russia will.

      1. Expat

        40% of Iranian exports of crude go to Europe. Iranian light is better than Saudi Light and Oman. Iranian Heavy is better than Saudi heavy. I don’t know what the grade splits are with regards to markets, but I believe it is mostly Iranian Light. As for light, sweet crudes from the rest of the Middle East, I am stumped to name a major source of sweet crude from the Middle East.

        Japan is the third or fourth largest market for Iranian crude in Asia. China and India import about 1.3 million bpd together. Japan imports about 7 million barrels per month.

        Iranian is fungible for the most part. While there are differences in yields and specific refineries may prefer an alternative heavy, sour crude, regionally it is easy to switch between various sour grades. Fresh sanctions only matter if enough buyers stop buying. Increased costs of shipping to new markets (say, more to China vs. India) are borne by NIOC. NIOC has already lowered prices to maintain market share and entice buyers to either ignore the sanctions or switch grades if they are not under sanction.

        US oil sanctions are designed to punish European and Chinese oil companies because the US companies can’t work in Iran. Iran has the largest gas reserves in the world and an oil infrastructure seriously in need of investment. It’s sour grapes.

        1. nervos belli

          Can you please show a link for these 40%? I found only an old image directly pre sanctions where approx 65 went to China, India, Korea, Japan, Indonesia and about 25% at most to Europe.

          1. Expat

            Various sources. Just search for Iranian oil sales to Europe, Iranian oil sales to China, etc.
            This is also what I do for a living so some of the sources are in my brain.

    2. nervos belli

      These oil rigs in the mediterranean only replace the declining oil and gas fields of the North Sea. Simple replacement, nothing gained but nothing lost either.
      The iranian oil goes to Asia, not the EU. It’s the oil and gas exploration, infrastructure and transport the european companies want in. They want to exploit the oilfields together with Iran and profit of them, they don’t want to use the oil for themselves.
      The way to transport resources from oil and gas from Iran (or Quatar) would need a pipeline through Syria, and right now they are still fighting a war there for which side, Iran or Quatar and by now Saudi Arabia and UAE is allowed to lay this pipeline. Obviously Iran is winning against S-A and UAE right now, but it will still take years, maybe even decades, before a pipeline can be built.
      Easier and far more profitable to sell to actually growing economies in the far east.

  3. pogohere

    Macron apparently laid out some details about EU approach that are worthy of note:

    Putin’s Big Economic Conference Is a Very Big Deal This Year

    “Macron said loudly and clearly that … France has the authority and the obligation to exercise its sovereignty and pursue an independent foreign policy. And … that trust between nations … is possible only when nations … assert their sovereignty.”

    Macron re-stated the commitment of the 3 European signatories of the nuclear accord to remain in the Agreement, despite the withdrawal of the United States. Here their interests coincide with Russia’s. Macron made reference to the decision the week before at the European Summit in Sofia to activate mechanisms that will protect the Agreement and also European companies from extraterritorial application of the American law on sanctions. In answer to questions from reporters on both days of his visit, Macron explained that compensation against losses imposed the US applied only to companies which are not quoted on US exchanges or otherwise heavily invested in US operations which might be shut down. That would entail unacceptable expenses for the European taxpayers. Accordingly such very large companies will decide for themselves on how to respond to US sanctions while small and medium sized companies could be protected. It remains to be seen whether this approach will be sufficient to ensure that Iran continues to benefit commercially from the Agreement in a way that justifies its continued participation. [emphasis added]

    1. nervos belli

      Would you as a company owner trust this utterance by a politician? This sounds to me like one of the many donor conferences for country x where billions of aid against catastrophe, hunger, whatever is promised and where the receiving country is lucky to get 10% in the endl.

      Also, small companies are not really affected or at least much less: they generally don’t play in international markets or the US that much. So they can, if they want to, more easily start their international operations with Iran. In fact, it’s actually a business opportunity for them since the big players are obviously unable to.
      It’s only big companies who already are selling to the US which cannot afford to lose the huge US market to gain the small iranian one.
      I’d be a lot more trusting to the blabbering of european politicians, here Macron, if they protected their big national corporations against these sanctions. But that is exactly what they are not doing. The proper way wouldn’t be taxpayer money to indemnify either, that is just utterly daft corporate welfare. Airbus already lost a few billions of dollars of sales due to the reneging of the US. So did Total in gas fields. Those are both quintessential french and european companies, you can’t get more “EU champion” than Airbus but Macron lets them hanging in the wind, having their undersides exposed.

      The proper way to do combat the US decision would be still trading with Iran a i nothing happened. Then if and when the US starts to sanction these companies for their lawful trading, then Europe would have to sanction Boeing and Exxon the same way: no sales in the EU for them. No more sales for Boeing to EU airlines, no more sourcing parts. No more sale of oil for Exxon in the EU. To make it ironclad, put it into a EU directive and law in all member states, so they cannot weasel out when the time comes or various countries (Poland for example…) would immediately fight it.

      Only if the EU is willing to go that far, I’d believe any bullshit blabber they are making now. They aren’t doing that however and that is telling.

  4. The Rev Kev

    Not so simple here – it never is. Take the example of Total having to get out of Iran’s South Pars field as mentioned in this article. Sure they did – and as they walked out the door they passed the Chinese and Russian oil companies walking in. That is not the end of it though. I read a few days ago that Total is going to use the money not spent in Iran to take part in a $25 Billion Russian Arctic LNG Project ( which will not make Washington happy. What is odd is that the writer never mentioned this in the present article as she also wrote the one on the Russian Arctic project.
    As they say – oil finds a way. In this case I would say that Iran’s oil will flow to China or perhaps to Russia for resale. And there will be no dollars involved in payment for this oil so the US will not be able to stop it. As for the Europeans. Whether they win or lose this battle there will be all sorts of repercussions. As an example, perhaps Europe will not be so forthcoming with military forces to conduct American projects and sanction patrols. Maybe a lot of American companies will find themselves losing European sales to other companies. Nothing overt but the word will get around. Trump may demand that Europe up there defense budget to 2% but if NATO countries do, maybe the contracts will be with European countries or others with no forthcoming contracts for US defense firms as Trump is expecting.
    It’s going to get interesting.

  5. PlutoniumKun

    My guess is that Europe (and Japan) will not be able to withstand US pressure over this – the damage to the US will be in the longer term, as there is no question that the Europeans and Asians will now be ensuring that the systems are in place to ensure they are not in future at the mercy of the whims of whatever nutcase the US elects as president. In Europe in particular, they know that if they lose giant contracts to China and Russia over, for example, aircraft supplies, they won’t get them back. Its a matter of self preservation.

  6. tc10021

    Not sure that using US systems or access to US markets is a God given right to Europeans or anyone.

    These comments seem more like the status quo bellyaching about their anticipated losses rather than real arguments, and I tend to lose interest in all comments that say stuff like,”…whatever nutcase the US elects as president….”. Sad that Yves allows that.

    1. Clive

      Like it or loath it, being a hegemon brings power and that power brings responsibility. Even being irresponsible is an overt action. Here in Britain we’re still mopping up the legacy of when we had a go at it through the Empire in political, economic and societal terms. That’s 60 years later — our relationship with our neighbours in Europe, former enclaves like the Republic of Ireland and ex-dominions like India and Hong Kong (and thus China) are fraught with the baggage we saddled ourselves with from that era. Even the union (of the UK, to be specific) is embroiled in this history arising from those actions.

      Sorry, but there’s no running away and hiding for the US from the consequences of its actions and the implications of its leadership.

      And rubbishey leaders are fair game for comments. Of course any outsider commenting on another country’s domestic matters is, in effect, doing a slightly titivated version of concern trolling (“what’s it matter to you? you don’t have to live here…” being a justified retort). But the US’s actions impact Europe and Asia. Tell the people of Iraq or Libya they don’t. Just as the UK’s actions impact Europe or Europe’s actions impact Russia (and so on).

      Plus you do well to listen to outside critiques because they often possess a clarity (through detachment) you, as a resident of the country in question, inevitably lack. Yves flagging up of crazy self-referential naval-gazing UK press on Brexit being just one of many good examples.

      1. Carolinian

        Thing is, Britain as a small island with limited resources at least had some excuse for pursuing an empire via its large navy. Here in America we are perfectly capable of feeding ourselves and manufacturing what we need. The post WW2 pursuit of hegemony and globalism seems to have been more about our own class warfare and expanding the power of a ruling class based along that Acela corridor. The US could happily manage in a multipolar world if only our elites were on board.

        Also, since misleading headlines are a peeve around here, I’d say the above article doesn’t really support the headline. Europe does have a choice of standing up to the US and the last time the 1996 law was invoked (in the case of Cuba sanctions) the US backed down.

        1. DHG

          The US is in no position to manufacture what it needs at all, neither is it capable of feeding itself anymore, its all illusion.

      2. tc10021

        I agree that well-written thoughtful comments are worth reading. “Rubbishey” comments that offer broad stroke condemnations, are, well, rubbish.

        As for Brits, Euros, name your lot, they all erect and maintain barriers to entry for people, trade etc based on fairly domestic, limited interests which are created by senior leaders accommodating a status quo interest.

        I reckon that some of the outrage we see , is simply a reaction to folks’ refusal to acknowledge their limits in influencing events beyond their doorstep.

        1. Clive

          That was the point of the article. The US can try to push the EU around. It will succeed in doing so unless the EU decided to resist. If it resists, there will be consequences for the EU. Those consequences will be both domestic and international. So it’s likely the EU will cave. That, however, is still the EU’s choice. But even if the EU decided not to dig its heels in, it will potentially have implications for EU-US relationships.

          I’m struggling to see why criticism of the US leadership which upped this particular ante isn’t an appropriate topic for discussion. Whether it was worth the US doing so definitely isn’t obvious. If something isn’t clear-cut, it’s an arguable point. The post explored the arguments.

      3. berit

        Excellent comment! Thank you, Clive! Being a hegemon brings power. Power entails responsibility!! Being irresponsible is an overt action impacting people, societies and our shared future in myriads of mostly not expected or forseen ways – for years and generations to come. Irresponsible US politicians and politics of dominance and war are impacting our shared world. We have every human right to look at this critically and express our opposition to the shortsighted, bellicose, irresponsible US hegemon parading the arrogance of its ruling moneyed, militarized cleptocratic system of government for all to see. European nations should use their power of sovereignty to resist the US hegemon, not act as spinelessly, shamelessly subservient as British poodle Blair and our equally subservient Norwegian NATO-poodle Stoltenberg. Power corrupts. Hegemonic power corrupts the host and us all – unless we resist.

    2. HotFlash

      stuff like,”…whatever nutcase the US elects as president….”. Sad

      The volatility of the currently-elected nutcase is quite germane to any discussion of what to do about it. The US might have elected a more single-minded but still not-well-thought-out-war mongering nutcase (eg, Bush, George W., or Clinton, Hillary R.) instead of the current not-well thought-out-tariff-and-sanction imposing nutcase, in which case other nations would have to take that into account. So you see, it *does* matter which nutcase the US has elected at any given time.

  7. Expat

    The US has enforced blocking laws of its own, notably with regards to embargoes on Israel.
    The EU has a choice. It can comply with new sanctions and lose all credibility as the US has. Or, it can stand up to Trump (this is Trump and a few others like Bolton) and continue to deal with Iran.
    The US would start proceedings against any European company trading with Iran and possibly seize assets at which point Europe would have to demonstrate it has a pair and retaliate against all US holdings including bases (either kick the US out or seal the bases). Frankly, I don’t think Europe has the nerve, which is a shame because I doubt even Trump would declare war on Europe.*

    *If Trump attacks Europe, would that engage the NATO treaty and therefore require that the US defend itself against itself? From a European point of view, this could be win-win if the US simply starts bombing itself.

    1. Carolinian

      The US has enforced blocking laws of its own, notably with regards to embargoes on Israel.

      Indeed. The “do as we say not as we do” hypocrisy here is quite striking. It’s almost as if Nikki Haley was running the government (we here in SC have abundant experience of how she rolls).

      Oh wait…..

    2. Jim Haygood

      The US has enforced blocking laws of its own, notably with regards to embargoes on Israel

      Where is the Israel nuclear deal?

      Lost in all the tactical questions about sanctions compliance is why the US considers distant Iran a bête noire when Iran is of so little geopolitical significance to the US.

      The answer, of course, is that US sanctions on Iran are aimed a punishing Israel’s regional enemy. US and European businesses bear the exorbitant costs of implementing AIPAC’s perennial hobby horse, on top of the direct cash subsidies the US sends to rich OECD Israel.

      Of course, we get so many benefits from our precedented generosity such as … erm, well … they are many and varied, I assure you!

      1. Chauncey Gardiner

        Excellent comment. As an American I have a basic question about why the sanctions have been reimposed in the first place?

    3. Oregoncharles

      “if the US simply starts bombing itself.” Don’t say that, they read this.

      And seriously: if you’re a Hanford or Nevada test site downwinder, you know that the US HAS bombed itself. A couple of nukes fell by accident., So not necessarily funny.

  8. liam

    I’m somewhat perplexed here. Is this very issue not one of the main points, (if not the main point), of the EU’s existence. Every time the question of loss of national sovereignty is raised, (and ask the Brits, because it does get raised, ad nauseum), the answer is that sovereignty is pooled, and by doing so preserves it. It is presented specifically as a check on US power vis-a-vis European states. To this voter, it’s the main benefit of EU membership. What gives?

    1. Clive

      You have, there, captured the essence of the tautology. Most every sovereign state (or quasi-state actors like the EU) like the idea of getting to exercise that sovereignty. But it takes finesse to avoid blowback. If the EU decided to go mooning Uncle Sam, he’s unlikely to see the funny side. But if you can’t tell the US to get over itself and it doesn’t rule the world, what is the point of the EU? Why not just acquiesce to what the US wants (until it changes its mind in the next 5 minuets)?

      It’s just an endless retread of the Brexi arguments I suppose. We’re “taking back control” though of what, exactly, from whom and why then paying what price — that’s not so clear cut. But that sort of thinking resonated with enough people to tip the referendum result to Brexit, so here we all are.

      1. liam

        Hmmm. You see this is where I both understand and disagree with Brexit. I understand, because the very essence of democracy is to retain power as close to the local sphere as possible. I disagree, precisely because of the hegemony the US has exercised over the past few decades, (chlorinated chicken anyone).

        Ironically, I’d figured that with Britain leaving the role of the EU would strengthen in this regard. I hadn’t thought that they’d capitulate in the face of fines on companies and corporations. I don’t understand the timidity.

      2. Carolinian

        The don’t rock the boat approach could make sense if you assume the present system will continue to maintain itself. On the other hand if “that which cannot continue will not” then perhaps the Brexiters have some merit and the loss of London’s financial power is something that was going to happen anyway.

        We provincial Americans hesitate to offer an opinion but the situation here isn’t necessarily all that different. We are told the sky will fall if major change is attempted. Since most people in these wealthy countries continue to get by stasis rules.

    2. Mel

      Pooled sovereignty is somewhat strange, as in “We’ll combine all our sovereignty and give it to those guys over there to run.”
      From the point of view of somebody like Lenin, the pooled sovereignty attaches all of Europe to one convenient handle for the benefit of whoever gets hold of the handle. The EU might be a check on US power, but it’s evidently no check on IMF power, and the IMF is run by the same transnational operators who run the US. So yeah: what gives?

        1. Mel

          States Rights took a beating during the Civil Rights Movement, when a lot of people decided that some states were — misapplying — their sovereignty.
          Not that transnational money seems to need to worry much about what any one state of the Union will think.

      1. makedoanmend

        Isn’t the United States of America an example of pooled sovereignty that has been around for a while? They rejected confederacy and took to federalism, though not without various ups and downs. (I think a one J Haywood has made some comments about this situation previously.)

        [ beat me to it Expat :-) ]

    3. nervos belli

      The EU is awesome when it comes to beating poor african nations with trade treaties. Much better than any single european nation would be capable of.
      The EU is similarly good just a bit less so, when dealing with the small leftover europeans like Switzerland or Norway.
      Or even doing advantageous free trade treaties with Canada.
      So you just have to choose carefully who to bully, and it’s all great being the EU.

      If the EU centralism grows a bit and not every single 5 million pseudo member will squeak, it might even one day be able to deal with the US as equal.

      1. berit

        … “leftover europeans like Switzerland or Norway”… Funny. I don’t know about the Swiss, but “every single 5 million pseudo member” will hardly squak, as more than 50 percent of us are convinced our culture is superior, according to NRK-news this gloriously superhot morning, as the only nation of 15 measured on this astounding feat of navle-gazing and busy titiating (word learnt today via NC) our well oiled wealth – oops – cultural – superiority … how did that come to pass, this leftover one wonders…

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