In November 2013, the P5+1 reached agreement on a Joint Plan of Action (JPoA) to suspend certain sanctions in exchange for Iran rolling back aspects of its nuclear programme. On Monday 20 January 2014, the JPoA came into effect. The EU enacted Council Regulation 2014/42 (the “Implementing Regulation”), which suspends relevant measures for a six month period. The US Department State has also issued detailed guidance in relation to the corresponding US relaxations.
Whilst the changes are significant, they are limited in scope and the majority of the EU/Iran and US/Iran sanctions remain very much in force. The US relaxations are subject to a number of conditions and limitations, and both sets of sanctions may be re-imposed even prior to the expiry of the 6 month period; the Department of State guidance makes clear that “the USG retains the authority to revoke this limited sanctions relief at any time if Iran fails to meet its commitments under the JPoA”.
Any companies planning to conduct business which would previously have been prohibited will need to have careful regard to the scope of the relaxations. In our briefing, we explain the key changes to the EU regime, and summarise the effect of the US relaxations.