Muddy waters

Mark Dunn, Market Planning Manager, Risk & Compliance, LexisNexis: +44 (0) 20 7400 2984, risk@lexisnexis.co.uk

At 10.30am on Monday 12 October, HM Treasury’s first ‘direction’ under Schedule 7 of the Counter Terrorism Act 2008 (CTA) - The Financial Restrictions (Iran) Order 2009 - came into force. In essence, writes Mark Dunn of LexisNexis, the direction requires that firms in the UK financial services sector do “[N]ot enter into or continue to participate in any transaction or business relationship” with two Iranian entities, Bank Mellat and the Islamic Republic of Iran Shipping Lines (IRISL) (or their branches), for 12 months. The Treasury issued the direction “[I]n response to the significant risk to the UK’s national interests posed by activity in Iran that facilitates the development or production of nuclear weapons.”