Extension Of The Sanctions Relief Provided For In The Joint Plan Of Action Between The P5+1 And The Islamic Republic Of Iran

On July 18, 2014, the P5+1 (the United States, the United Kingdom, Germany, France, Russia, and China) agreed with Iran to extend their commitments under the Joint Plan of Action (JPOA).  The JPOA, originally agreed upon in November 2013, aims to curtail the development of Iran’s nuclear program.  Under the JPOA, the P5+1 have agreed to undertake a number of voluntary measures, including the temporary and limited suspension of certain sanctions, in exchange for certain commitments by Iran.  The relief provided under the JPOA has now been extended to November 24, 2014, during which time the P5+1 will continue to work with Iran to reach a final agreement.  The JPOA can be found here.

Pursuant to the JPOA, the U.S. has agreed to continue to provide limited sanctions relief with respect to Iran’s export of petrochemical products, automotive and aviation industries, purchase and sale of gold and other precious metals, civil aviation industry, export of crude oil, as well as certain efforts relating to the facilitation of humanitarian relief.  The relaxation of such sanctions continues to apply only to non-U.S. persons; U.S. persons and U.S. -owned or -controlled foreign entities continue to be generally prohibited from conducting transactions with Iran unless licensed to do so by the Office of Foreign Assets Control (OFAC).  In addition, such relaxation applies only to certain transactions conducted and fully completed between July 21, 2014 and November 24, 2014.  OFAC has issued guidance on how the extension of the JPOA will be executed and administered.  A copy of the guidance and other relevant documents, including a list of frequently asked questions, can be found here.

As before, the U.S. has emphasized that it will continue to vigorously enforce sanctions against Iran that are not subject to relaxation under the JPOA and that it retains the authority to revoke the limited sanctions relief provided under the JPOA at any time if Iran fails to meet its commitments.


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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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