On January 16, 2016, the International Atomic Energy Agency (“IAEA”) announced that Iran has fully implemented its nuclear-related commitments described under the Joint Comprehensive Plan of Action (“JCPOA”) bringing about Implementation Day under the agreement. The JCPOA is an agreement between the EU, the P5+1 countries (China, France, Russia, the United Kingdom, the United States, and Germany) and Iran under which the EU and the P5+1 countries provided Iran sanctions relief in exchange for commitments from Iran to scale back its nuclear program. Implementation Day, the second stage of the JCPOA, obligates the United States and the EU to cease the application of a number of nuclear-related sanctions against Iran.

The main impact of Implementation Day in the United States is to cease the application of certain types of nuclear-related secondary sanctions to nonU.S. persons (i.e., individuals who are not U.S. citizens or permanent residents, companies that are not incorporated in the United States, and persons who are not located in the United States). U.S. companies also will see some limited sanctions relief as a result of Implementation Day, as specific licenses may be issued by the U.S. Government for certain transactions involving commercial passenger aircraft, and the importation into the United States of Iranian carpets and foodstuffs may be authorized under a general license. Non-U.S. companies that are owned or controlled by a U.S. company also will be able to engage in more activities involving Iran under a new general license.