US and EU Mark "Adoption Day" of Iran Nuclear Agreement
While US and EU Mark Adoption Day of
the Iran Nuclear Agreement,
Current Sanctions Regime on Iran
By Glen Kelley, Doug Jacobson and Michael Burton, Jacobson Burton Kelley PLLC
Iran must now satisfy its
extensive obligations to scale back its nuclear activities, and the US and EU have formally begun preparing to ease
sanctions next year if Iran US
By Glen Kelley, Doug Jacobson and Michael Burton, Jacobson Burton Kelley PLLC
We continue to follow the gradual progress by the United
States , the EU, Iran
and other countries towards the implementation next year of sanctions relief
under the July 2015 agreement with Iran
Our most recent post on Iran
Adoption Day and Implementation Day
Yesterday, October 18, the United States
and the EU marked “Adoption Day”, a milestone that follows
several initial steps by the US ,
EU and Iran
It is important to note that none of the sanctions relief will be effective
until Iran
Once Iran
As we noted in our previous alerts, even if the JCPOA is fully implemented, very
little will change with respect to the broad US
embargo of Iran Iran ,
its government, and many targeted Iranian companies will remain prohibited if US
If the JCPOA is implemented next year, the EU will lift the majority of its
sanctions on Iran , and the US
Key US and EU Documents
The principal legal instruments and guidance issued on October 18 in relation
to the anticipated US and EU sanctions relief are as follows:
- The US Treasury Department's Office of Foreign Assets Control (“OFAC”) issued guidance on frequently asked questions (“FAQ”) related to JCPOA implementation. These are available at http://1.usa.gov/1hM0zdj.
- The US State Department issued “contingent waivers” of the
- A Decision and two implementing Regulations issued by the Council of the European Union, setting out the precise parameters of the EU sanctions that will be lifted if Implementation Day is reached. These are available at http://bit.ly/1XdKvRy.
There is little that is new or unexpected in the documents released by the US
- Until Implementation Day, non-US persons could be penalized by the
- If
- Many of these Iranian government entities play an important role in the Iranian
economy, so it will be important to know whether they can be involved in
transactions carried out pursuant to any JCPOA sanctions relief that is
implemented next year. The new State Department guidance suggests that these
entities could be involved in transactions that are authorized pursuant to the
JCPOA, including any export from the
- On the other hand, it appears from the State Department guidance that the
- The Joint Commission called for under the JCPOA, consisting of high-level
representatives of the US, EU, Iran and the five other countries party to the
JCPOA, has been formed and will have its first meetings this week. The
commission may soon begin hearing complaints from both sides that actions are
falling short of commitments, for example by Iran regarding the anticipated US
sanctions relief, and by the other parties regarding Iranian action to
dismantle its nuclear program and other Iranian actions. The
Conclusion
OFAC has reiterated on numerous occasions that it intends to publish on its
website detailed guidance on the implementation of US sanctions relief under
the JCPOA. We expect this to be posted several weeks before Implementation Day
occurs next year.
We will continue to monitor the sanctions relief under the JCPOA and will issue
further updates when significant developments occur.
Labels: Export Controls, OFAC, Sanctions; Iran
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