Saturday, 16 January 2016 marked Implementation Day of the Joint Comprehensive Plan of Action (JCPOA) between the the E3/EU+3 (China, France, Germany, the Russian Federation, UK and US, in conjunction with the High Representative of the European Union for Foreign Affairs and Security Policy) and the Islamic Republic of Iran (Iran). On Implementation Day, the International Atomic Energy Agency (IAEA) verified that Iran had implemented its key nuclear-related measures described in the JCPOA. In the US, Secretary of State John Kerry confirmed the IAEA’s verification, and the US and EU simultaneously lifted certain agreed-upon nuclear-related sanctions.
We previously published an Alert on this matter, The Iran Deal: What’s In It and Who Will It Impact, which provided a substantive overview of the JCPOA’s provisions. This Alert, rather than reiterating those provisions, highlights key components of the US and EU sanctions relief that took effect on Implementation Day and raises practical considerations for companies that consider conducting business with or involving Iran.