The Significant Reduction Exception “SRE”: an aborted project

It is almost five months since the US Secretary of State Michael R. Pompeo – on November 5, 2018 – announced that Italy would have been among the countries taking benefit from the SRE (i.e. the possibility to continue the imports of Iranian oil for a further period of six months).

At the same time, OFAC had raised the option of transferring the consideration paid for the purchase of oil – in the SRE regime – in a special purpose account at an Italian bank where, subsequently, the price of different export operations of Italian companies towards Iran could have been charged.

Unfortunately, within one month of the expiry of the SRE regime, the special purpose account has not been created and, apparently, this will never happen. Therefore, in spite of the enthusiastic reaction of public opinion, the project must be considered substantially failed.