On 16 January 2016, or "Implementation Day", legislation in the United States ("US") and European Union ("EU") came into effect, relaxing significantly the sanctions in place against Iran. This followed the issuing of a report by the International Atomic Energy Agency ("IAEA") to the UN Security Council, confirming that Iran had complied with its commitments under the Joint Comprehensive Plan of Action ("JCPOA").
In this bulletin, we set out the key changes to the sanctions regimes and consider potential implications for business. For further information, please contact Joanna Addison, Partner, Andrew Cannon, Partner, Jonathan Cross, Of Counsel or any of the individuals listed in the bulletin.
The Joint Comprehensive Plan of Action relating to Iran's nuclear programme (the "JCPOA") officially came into effect on 18 October ("Adoption Day"), requiring all JCPOA participants to make the necessary arrangements and preparations for implementation of their respective JCPOA commitments. In this briefing, we summarise the most recent steps taken by the US and EU under the JCPOA.
In the case of both the EU and US, there have been no immediate changes to the legislative position and all sanctions continue to apply.
For further background on the JCPOA, please see our previous briefing.
Our full e-bulletin is available here.
For more information, please contact Susannah Cogman, Partner, Daniel Hudson, Partner, Jonathan Cross, Of Counsel, Elizabeth Head, Senior Associate, Justin Schenck, Associate or your usual Herbert Smith Freehills contact.