Following President Trump’s decision on 8 May, 2018 to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), the US government announced that it would re-impose pre-JCPOA nuclear-related Iran sanctions (both primary and secondary) that were lifted under the JCPOA. As we reported previously, two “wind-down” periods—of 90 and 180 days respectively—commenced from the day of the announcement, during which non-US, non-Iranian companies were encouraged by the US government to withdraw from operations in Iran that would be affected by re-imposed sanctions. OFAC’s guidance discouraged non-US persons from engaging in new activity during the wind down periods, and stated that any such new activity may be a factor in connection with future enforcement action for actions taken after the wind-down period.
Tag: Joint Comprehensive Plan of Action
Herbert Smith Freehills is pleased to announce the publication of an updated version of its Iran Investment Guide. The guide describes the key legal aspects that foreign investors should consider when investing in Iran. It has been updated to take into account the lifting of the EU's nuclear related sanctions and most of the US secondary sanctions following the occurrence of "Implementation Day" under the Joint Comprehensive Plan of Action.
Since the announcement of the Joint Comprehensive Plan of Action ("JCPOA") in July 2015, companies have been preparing for the relaxation of sanctions that will allow them to re-enter Iran. As Implementation Day (the point at which some sanctions will be relaxed) approaches, the UK's Foreign & Commonwealth Office (the "FCO") has updated its guidance on doing business with Iran to assist British companies looking to take advantage of this new opportunity. The updated document includes guidance, among other things, on entry into MOUs or conditional contracts relating to currently prohibited activity prior to Implementation Day.