Implementation Day under the Joint Comprehensive Plan of Action signed by the P5+1 (United States, United Kingdom, France, Russia, China and Germany), the European Union, and Iran (“JCPOA”) came on January 16, 2016 and certain nuclear-related secondary sanctions on Iran have now been lifted. With three notable exceptions, the partial lifting of sanctions do not apply to US persons and US companies, who continue to be broadly prohibited from engaging in transactions or dealings with Iran and the Government of Iran unless such activities are exempt from regulation or authorized by the Office of Foreign Assets Control (“OFAC”). However, the US has now removed restrictions on formerly prohibited activities of non-US entities owned or controlled by U.S. persons, which represents a significant development.

Far from marking the return to business as usual between the United States and Iran, Implementation Day inaugurates a no less challenging phase in the complex US relationship with Iran. As if to underscore this fact, only one day after partial lifting of nuclear-related sanctions on Iran, OFAC imposed new sanctions on specific individuals involved in Iran’s ballistic missile development program.