The temporary and limited changes to U.S. and European Union (“EU”) sanctions policy for Iran, as agreed under the interim nuclear deal reached by Iran and the P5 + 1 countries, have been extended until June 30, 2015. Most U.S. and EU sanctions on Iran remain in place and will continue to be enforced. Until June 30, 2015, non-U.S. individuals and companies (unless U.S. owned or controlled) will not face U.S. sanctions enforcement if they engage in specified transactions relating to: (a) the export of Iranian petrochemical products, (b) the provision of goods and services for Iran’s auto industry, (c) the sale of gold and precious metals to or from Iran, and (d) the provision of insurance and transport services associated with sales of Iranian oil to six specified countries. The U.S. government has continued the favorable licensing policy for the provision of goods and services to Iran’s civil aviation industry by U.S. persons, U.S. owned/controlled foreign entities and non-U.S. persons. The U.S. also is taking steps to facilitate certain humanitarian and medical trade with Iran, payment of UN dues and support for Iranians studying abroad.

The P5 + 1 (U.S., UK, France, China, Russia and Germany) reached an interim agreement (the “Joint Plan of Action,” or “JPOA”) with Iran on November 24, 2013 in connection with negotiations aimed at limiting Iran’s uranium enrichment and potential for nuclear weapons development. The sanctions changes addressed in the Joint Plan of Action are temporary and will be maintained only during negotiations and while Iran continues to meet its reciprocal obligations.