The latest on Russia sanctions from the International Trade and Supply Chain Team
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On July 14, 2015, following nearly twenty months of talks, international negotiators from seven countries (the United States, the United Kingdom, China, France, Germany, Russia, and Iran) announced that they reached a landmark nuclear agreement to limit Iran’s nuclear program. While this is a historic agreement long in the making, it is important to note that there is no immediate lifting of sanctions against Iran. U.S. government officials have indicated that for now it is status quo for those focused on sanctions compliance.

Under the new Joint Comprehensive Plan of Action (JCPOA), Iran commits to decrease its number of centrifuges by two-thirds, significantly reduce its uranium stockpile (by approximately 98%) over 15 years, limit its research and development for a period of eight years and refrain from building any heavy-water reactors for 15 years. Further, Iran’s breakout time needed to amass enough nuclear material to building a bomb would be extended to one year.

In exchange for Iran’s commitments under the JCPOA, the United Nations (UN) Security Council agrees to pass “without delay” a resolution endorsing the agreement. In the United States, the Congress has sixty (60) days to review the terms of the proposed deal once the text of the JCPOA is transmitted to lawmakers. President Obama has pledged to veto any effort to derail the agreement. Ninety (90) days after the UN approves the JCPOA, referred to as “Adoption Day”, the United States, European Union and other parties to the deal agree to set the lifting of certain sanctions in motion.

Any sanctions relief, however, will only be phased in after Iran proves to the International Atomic Energy Agency (IAEA) that it is meeting its obligations under the JCPOA. The restrictions that would be lifted include oil embargoes and certain banking sanctions, as well as a ban on exports of civilian aircraft parts to Iran. The U.S. trade embargo with Iran will not be lifted immediately by the JCPOA and Americans, foreign subsidiaries of U.S. companies, and U.S. financial institutions will still be largely prohibited from dealing with Iran. If Iran violates any aspect of the JCPOA, the UN sanctions will be reinstated for 10 years with the possibility of a five-year extension.

Under the JCPOA, the United Nations will lift its arms embargo after five (5) years and its ballistic missile embargo after eight (8) years provided the IAEA certifies that “all nuclear materials in Iran remain in peaceful activities.” The IAEA is tasked with ensuring that Iran meets the terms of the JCPOA. In addition, an eight-member Joint Commission comprised of representatives from the P5+1 nations, the European Union and Iran will be established to monitor compliance. Should the commission be unable to resolve a dispute, it will be referred to the UN Security Council.

Verification from the IAEA will mark the official “Implementation Day,” upon which the United States will begin suspending its sanctions against Iran. The Joint Plan of Action (JPOA) dated November 24, 2013 has been extended from July 14 until Implementation Day. This JPOA affects only Iran-specific sanctions relief and will be in place until the U.S. government issues official guidance on how to proceed when Iran has sufficiently met IAEA standards and sanctions are lifted.

We will continue to monitor developments as this new agreement moves through the approval and implementation process. Should you have any questions related to the JCPOA or other economic sanctions related matters, please contact Cortney Morgan.