After almost two years of negotiations, on 14 July 2015, the E3/EU+3 (China, France, Germany, Russia, the United Kingdom and the United States) and Iran reached an agreement regarding Iran's nuclear program. The Joint Comprehensive Plan of Action ("JCPOA") lays out a framework for Iran to dismantle much of its nuclear program in exchange for lifting certain United Nations ("UN"), European Union and US sanctions against Iran.
Financial and energy sanctions are lifted earlier—The agreement provides for financial and energy sector-related sanctions to be lifted before certain arms-related sanctions. The purpose of lifting these sanctions is to enable payment mechanisms for Iran to export petroleum-related products. A range of these sanctions can be lifted as early as 15 December 2015, when the International Atomic Energy Agency ("IAEA") is scheduled to verify that Iran has taken measures in accord with the JCPOA.
No sanctions are lifted today—The JCPOA provides for the gradual lifting of sanctions over the course of ten years provided that Iran continues to meet its commitments regarding its nuclear program.
Section 219 disclosure obligations remain—SEC disclosure obligations under the Iran Threat Reduction and Syria Human Rights Act with respect to transactions or dealings with Iran do not appear to have been changed by the JCPOA.
UN sanctions "snap back" provision—The deal lays out a framework for dispute resolution and a mechanism for the UN sanctions to be re-imposed in the event that Iran does not adhere to the terms of the deal. However, the sanctions would not apply retroactively to any business contracts signed with Iran while sanctions were lifted.
Our related client publications, which include a timetable for the implementation of the JCPOA, are available at:
http://www.shearman.com/en/newsinsights/publications/2015/07/lifting-of-sanctions-against-iran ;
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