The announcement by the International Atomic Energy Agency on January 16, 2016, that the Government of Iran has satisfied its commitments under the Joint Comprehensive Plan of Action (“JCPOA”), has triggered “Implementation Day” and the lifting of Iran sanctions as detailed in the JCPOA. This extraordinary event offers tremendous opportunities for Iran to reengage with the global economy and for non-U.S. companies to engage in business with Iran. In sum, as of Implementation Day:

..The European Union (“EU”) has lifted the substance of its economic and financial sanctions imposed in relation to the Iranian nuclear program and only a limited number of restrictive measures, including the listing of certain individuals and entities, will remain in effect under the EU Iran sanctions regime...