On December 15, 2016, the Office of Foreign Assets Control (“OFAC”) in the Department of the Treasury amended its Frequently Asked Questions guidance document (“FAQs”) regarding the Joint Comprehensive Plan of Action...more
Privy Council clarifies the nature of arbitration clauses, but uncertainties about the clauses’ effect still remain. “Non-exclusive” arbitration clauses provide that disputes “may” be referred to arbitration (rather than...more
Implementation Day Arrives: Sanctions on Iran are Lifted - Status update on the effect to US and EU Sanctions - Implementation Day – the day the International Atomic Energy Agency (“IAEA”) announced that Iran had...more
Even in light of EU and US relaxation of sanctions against Iran after Implementation Day, non-US Persons should evaluate any proposed dealings with Iran to make sure such activities do not violate any new or continuing...more
With “Implementation Day” came the lifting of certain key U.S. and EU sanctions on the civil aviation industry. However, many prohibitions still remain, and licensing requirements may attach to U.S. persons or non-U.S....more
U.S.-Iranian relations took a major step forward on January 16, 2016, with the arrival of “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA). Although this may present new business opportunities in...more
Editor’s note: This article includes news developments through January 18, 2016. The historic agreement that the P5+1 (the United States, the United Kingdom, France, China, Russia and Germany) and the European Union...more
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...more
In recent days, the news has been full of stories referring to the “end” or “lifting” of U.S. sanctions against Iran, actions that were taken after the International Atomic Energy Agency confirmed on January 16, 2016, that...more
On 16 January 2016, the United States and the EU lifted certain sanctions against Iran in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreed among Iran, China, France, Germany, the Russian Federation, the...more
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...more
As widely reported, Saturday, January 16 was “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA), agreed to on July 14, 2015, by the P5+1 (China, France, Germany, Russia, the United Kingdom and the...more
The impact of Implementation Day will vary depending on whether you are a US Person, a US-owned or controlled Foreign Entity, or a Foreign Person with no US nexus—what’s your status? ...more
This Saturday, January 16, 2016, the International Atomic Energy Agency (IAEA) certified that Iran satisfied their obligations under their nuclear-related interim obligations under the Joint Comprehensive Plan of Action...more
On January 16, 2016, the United States, its negotiating partners and Iran announced the arrival of Implementation Day for the Joint Comprehensive Plan of Action (JCPOA), to which the parties agreed on July 14, 2015 with...more
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...more
The EU and UN terminate most of their sanctions on Iran, while the US implements more limited changes to its longstanding embargo. On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran...more
Reading the headlines in this week’s Sunday papers regarding Implementation Day for the Joint Comprehensive Plan of Action (“JCPOA”), better known as the Iranian Nuclear Deal, one could be forgiven for believing that the...more
On Saturday, 16 January 2016, the International Atomic Energy Association (IAEA) submitted a report to the United Nations Security Council (UNSC) certifying that Iran has satisfied its obligations under the Joint...more
The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more
Editor’s note: This article was updated on July 23, 2015, to Editor’s note: This article was updated on July 23, 2015, to reflect certain additional information in U.N. Security Council Resolution 2231. On July 14, 2015,...more