The United States, United Kingdom, Germany, France, Russia and China (known as the “E3 / EU+3”) and Iran this week reached an agreement on the final text of a Joint Comprehensive Plan of Action (JCPOA) to provide that Iran’s nuclear program will be exclusively peaceful. With the JCPOA, there would be a comprehensive lifting of all worldwide sanctions related to Iran’s nuclear program including steps on access in areas of trade, technology, finance and energy.
Read a July 2015 report prepared by the KPMG member firm in the Netherlands.
Under the JCPOA, the sanctions against Iran will be lifted in a phased approach, according to the following “milestones”—
At this point, it is unclear when “implementation day” will be. There are many factors that can influence this, such as the time needed by the IAEA to verify whether Iran has taken all of the key nuclear-related steps stipulated in the JCPOA, and the time needed to overcome any legislative hurdles. For this reason, it is unclear when the lifting of the sanctions will take effect. According to unconfirmed statements by EU officials, this will be in five to 10 months.
Until that time, the EU and U.S. sanctions will remain in place, with the exception of the limited sanction relief agreed by the E3/EU+3 and Iran in the Joint Plan of Action (JPA). One of the more interesting examples of relief included in the JPA is the suspension of the prohibition on the import, purchase or transport of Iranian petrochemical products including related services (e.g. financing and insurance).
Companies can, in the meantime, consider what future opportunities may open up on the Iranian market.
Note that even once sanctions have been lifted, certain goods will remain subject to EU and/or U.S. export control regulations and therefore will still require prior export authorization from the relevant authorities (military and dual-use items). Companies need to keep this is mind and take the necessary export control compliance measures.
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