First EU Steps to Prepare for Sanctions Relief under Iran Deal

On July 31, 2015, the European Union (EU) adopted the first measures to prepare for the implementing of the Joint Comprehensive Plan of Action (JCPOA) with Iran by allowing EU Member States to authorise certain activities and transfers directly related to specific Iranian nuclear activities, subject to strict conditions, including prior notification to the United Nations (UN) Sanctions Committee.

JCPOA Timelines -

On July 14, 2015, the P5+1 (China, France, Russia, the United Kingdom, and the United States (US) plus Germany), the EU and Iran announced their agreement on the JCPOA, which was endorsed on July 20, 2015 by the UN Security Council (UNSC) in Resolution 2231 (2015).1 For more information on the JCPOA and Resolution 2231, click here for our client alert of July 21, 2015. Importantly, the JCPOA provides for an implementation plan (see attached flowchart), requiring the JCPOA participants to start making the necessary legal and administrative preparations for the implementation of the JCPOA by “Adoption Day” (occurring around October 18, 2015). The adoption of Council Regulation (EU) 2015/13272 and Council Decision (CFSP) 2015/13363 on July 31, 2015 marks the first step in the EU’s JCPOA implementation process. Both measures took effect on August 2, 2015. They are intended to allow certain activities related to the Fordow and Arak facilities, the export by Iran of enriched uranium in excess of 300 kilograms in return for natural uranium, and – subject to prior UN approval – certain other nuclear-related activities.

Please see full alert below for more information.

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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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