France or Germany possible hosts for SPV as EU looks to reward Tehran for nuclear deal

A special clearing house designed to allow European companies that trade with Iran to bypass newly reimposed US sanctions will be set up in Europe within months, possibly in France or Germany.

The clearing house, known as a special purpose vehicle (SPV), is seen as critical to reassuring Tehran that the EU genuinely wishes to reward Iran for signing the 2015 deal on its nuclear programme by expanding business with the country.

Under the terms of the deal, Iran agreed to limit its nuclear activities and submit to international inspections in return for the lifting of economic sanctions,

Donald Trump pulled the US out of the deal earlier this year, breaking with Europe, and on Monday a full panoply of US sanctions came into force. The package included the threat to sanction companies or countries that buy Iranian oil, the lifeblood of its economy.

The Iranian deputy foreign minister, Kazem Sajjadpou, speaking in London, expressed his frustration at the pace with which the SPV is being set up, saying: “What is lacking is both speed and efficiency.”

Tehran had been hoping for an announcement at the weekend on the next steps for the SPV, which was announced in principle two months ago.

The SPV would serve as a barter exchange neither connected to the US dollar-denominated international financial system nor requiring monetary transfers between EU countries and Iran. An Iranian firm selling into Europe would accumulate credits that could be then used to buy a product from a different European firm.

The three main European signatories to the 2015 deal – France Germany and the UK – are still working through the detailed implications of the US move. Key areas of concern include threats to humanitarian trade and the ability of Iran to access income from those countries granted a waiver to continue purchasing oil from Iran for at least six more months.

There has also been speculation that no European country has been willing to act as the host for the SPV, fearing US reprisals. The UK was always unlikely to be a site for the SPV, both due to the legal complications of Brexit and the need for the SPV to trade in euros.

Western sources, however, said candidates have come forward and details including the structure of its board and shareholdings were being discussed. The bulk of the technical negotiations with Washington have been led by France.

Officials are working through how a SPV would protect, for instance, a German firm operating in the US from secondary sanctions.

A failure to set up the SPV would be a humiliation for broader advocates of greater European economic independence from the dollar such as the French finance minister, Bruno Le Maire. Supporters of the SPV regard the imposition of secondary sanctions on European companies in pursuit of its foreign policy goals as an illegitimate demonstration of US economic imperialism.

The US has largely been dismissive of the SPV. The US special representative on Iran, Brian Hook, said: “We have not seen much, if any, demand for the SPV. We do not anticipate any significant corporation using a SPV.”

The EU foreign affairs chief, Federica Mogherini, said trade between Iran and the EU was “a fundamental aspect of the Iranian right to have an economic advantage in exchange for what they have done so far, which is being compliant with all their nuclear-related commitments”.

A number of Iranians, including celebrities, have condemned online the reimposition of sanctions, using the hashtag # SanctionsTargetMe.

The fashion photographer Reihane Taravati said: “This campaign aims to clarify the fact that the US sanctions target people of Iran.”

The film director Abdolreza Kahani tweeted: “War crime is not just killing people with mustard gas. Putting sanctions on drugs is the biggest chemical crime against humanity sanctions on Cytarabine, Doxorubicin & other medicine needed for chemotherapy/cancer treatments, is the biggest crime against humanity.”





