After years of fitful progress and failure, Iran and the five permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom, and the United States) and Germany (collectively the “P5+1”) reached a tentative, incremental, and interim deal on November 23, 2013. The Joint Plan of Action (the “JPA”) proposes contingent economic relief measures to Iran, provided Iran takes measurable and verifiable steps to limit its nuclear program. Although the JPA itself does not modify any of the existing sanctions laws and regulations nor authorize any specific transactions or trade with Iran, below we provide some practical analysis for persons (US and non-US) contemplating doing business with Iran in the near future.

What You Need to Know -

The proposed changes to the international sanctions regimes (both US and EU) are not presently in effect. All current US sanctions will continue to apply until Iran takes measureable steps that are verified by the International Atomic Energy Agency (“IAEA”). The JPA is contingent upon Iran fulfilling its obligations, i.e., the prerequisites of any lifting of economic sanctions targeting Iran must be fulfilled, and no sanctions will be suspended until Iran complies with its obligations.