Compliance Initiative

Play by the Rules Initiative: Iran 

In 2012/2013 many instances has been raised and put to our attention that a necessity of clarification upon agreed procedure, practices and understanding was needed in the spirit of full cooperation between allied countries as strategic response to threat of non compliance with existing complex layers of regulations.

EU entities wish to maintain maximum legal and ethical certainty within the EU and USA concerning the application and implementation of Sanction on IRAN, thus promoting a full international compliance culture.

Mid of 2012 EIFEC has issued a Road Map with a proposal for implementing Play by the rules initiative for IRAN.

A comprehensive Request for Clarification and Opinion document (RFCO) has been presented to US Government ( OFAC and BIS), to European Commission and to the EU Member state Ministry of Finance chosen as Pilot Project Country.

The RFCO has been progressively adapted in accordance with new regulations and discussions held with relevant authorities and stakeholders.

The problem to address:

The Sanctions are de facto affecting not only sanctioned goods or persons and organization but all iranian people and even items which are essential to the livelihood as medicines, food, agricultural products and legitimate or authorized commercial trade, are very difficult to deliver as the payments processes are almost blocked.

Who is compliant with the regulations and accepts to “play by rules” that EU and USA have laid down should not be de facto discriminated or discouraged but treated with equality to any other rights holders in our countries.

Therefore in order to allow people and organizations that are in accordance and compliance to EU/USA Regulations to transact in verifiably and orderly way the initiative “play by the rules” will readdress the non compliant situation de facto created by misunderstanding between the actors where who wish to play by the rules cant play as almost no one wants to play. the recognition and promotion of the good of each individual is a specific duty for every person.

The order of justice is not static but dynamic, because the very life of individuals and communities is in itself dynamic.
The Proposed action in short:

(i) Five (5) EU banks will have the possibility to maintain or open a corresponding bank account to a maximum number of 5 NON EU LISTED /NON US SDN private reputable iranian banks (hereinafter “IRANBANKS”) (ii) EUBANKS may receive on these accounts funds and any other permitted financial instrument to be used only for the payment of: a. Foodstuff b. healthcare, c. medical equipment d. humanitarian purposes e. Goods with authorization (the EU Member State Ministry of Economy and Finance (iii) The EU authorities will facilitate these financial channel for humanitarian trade. (iv) Specific schemes for maintaining the highest transparency and compliance have been outlined. The benefits. (i) The major benefit is the maintenance of maximum legal and ethical certainty for organizations in EU that will act accordingly to this initiative. (ii) Encouraging people and organization to comply laws easing the way to do it is an act of justice. (iii) No cost are involved will derive from this initiative (iv) Will allow the people of Iran to access again the food and agricultural products, medicine, medical devices, and medical expenses, without the burden of black market.

This Initiative has been object of several agreements.
In Iran several EU Export Compliance Agreements (EU-ECA) have been inked with the Red Crescent Society of Iran and The Central Bank of Iran ( Bank Markazi).

EU USA IRAN Plan of Action 24/11/2013
EU RFCO - Play by the Rules Initiative Document
USA RFCO Play by the Rules Initiative Document
EU Road Map - Play by the Rules Initiative: Iran

EIFEC is pleased to record that a Joint Plan of Action between EU, USA, Russia, China, Germany has been signed in Geneva on 24th November 2013.
In this JPOA has been included (pag.3) the principle to establish a financial channel to facilitate humanitarian trade.

It was the goal of the Play by Rules Initiative of EIFEC.

EIFEC has been promoting a justice principle – inter alia – incorporated in a global multi stakeholders action plan which took the name: Play by the Rules Initiative.

In a globally integrated world, efficient Export Compliance and Control with laws is only possible with co-operation at an European and international level.
All the parties involved expect this process to be transparent and to take place in compliance with the law, regulations as well as in due respect of ethical principles.

The key justice principle promoted is: Parties believe that whoever acts accordingly and in full compliance to rules, laws, legislations, regulations, authorizations, should be not discriminated or disadvantaged / disparage with others, to achieve their legal, compliant and legitimate pursue of business activity.

In short, whoever give rules to be follow must assure that recipients, not only must but, can play by the rules they have given. A valid principle applicable from children playground up to State Regulator activity.






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The main areas covered are the threat of nuclear, biological and chemical armaments proliferation, sanctions, AML, Health Emergency Risk in epidemic context.