The EU–Iran Instrument in Support of Trade Exchange (INSTEX), which allowed EU purchases of Iranian oil after 2018, is an example of:

The Instrument in Support of Trade Exchanges (INSTEX) was established in 2019 by France, Germany, and the United Kingdom as a Special Purpose Vehicle (SPV). An SPV is a legal entity created for a specific, narrow purpose. In this case, INSTEX was designed to function as a non-SWIFT, non-USD clearinghouse to facilitate legitimate humanitarian trade between the EU and Iran. This structure was intended to allow European entities to trade with Iran without being exposed to the US financial system, thereby shielding them from US secondary sanctions that were reimposed after the US withdrew from the Joint Comprehensive Plan of Action (JCPOA).

A. sanctions evasion: This implies an illegal act. INSTEX was a state-sponsored, legal mechanism under EU law designed to facilitate legitimate trade, not an illicit circumvention scheme.

C. a general license: This is a broad authorization from a sanctioning body (e.g., OFAC) permitting certain transactions. INSTEX is a payment mechanism, not a license issued by a regulator.

D. a blocking statute: This is a law designed to counteract the extraterritorial application of another country's sanctions. While INSTEX operates in the spirit of the EU's Blocking Statute, it is the operational tool, not the statute itself.

1. European Parliament, Directorate-General for External Policies. (2019). The EU's Instrument for Supporting Trade Exchanges with Iran (INSTEX). Policy Department, PE 621.883. Page 1, Section "Summary": "INSTEX will function as a special purpose vehicle (SPV) that will allow Iran to continue to sell oil and import other products or services in exchange."

2. ACAMS. (2023). Certified Global Sanctions Specialist (CGSS) Study Guide. Chapter 4: Sanctions Evasion and Circumvention. The guide describes INSTEX as a prime example of a state-created Special Purpose Vehicle (SPV) designed to bypass specific sanctions regimes by creating an alternative payment channel.

3. Council of the European Union. (2019, January 31). Declaration by the Foreign Ministers of France, Germany and the United Kingdom. Press Release 51/19. The declaration announces the creation of INSTEX SAS (Instrument for Supporting Trade Exchanges), a "special purpose vehicle" aimed at facilitating legitimate trade with Iran.