Three EU governments have created an SPV which would enable companies to trade with Iran without breaking sanctions.
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When the U.S. withdrew from JCPOA, it said that companies breaking the reimposed sanctions would face stiff penalties. Among the companies the U.S. administration listed as potential sanctions-breakers was the Brussels-based international messaging service SWIFT, which is the lifeblood of international payments. In November, evidently concerned about the potential consequences for global payments if the U.S.
On the Iranian side, INSTEX is mirrored by a similar SPV, known as STFI. STFI would likewise match incoming and outgoing transactions. So the two Iranian entities would also effectively pay each other. Thus, everyone would receive their goods and payments, but no money would cross the Iranian border.
Secondly, as the JCPOA statement indicated, the aim is to open INSTEX to third countries. China and Russia were both present at the meeting, and both have an interest in trading with Iran. Crucially, their trade could include oil. The European Council on Foreign Relations observes that
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