A critical date related to sanction relief for Iran is 18 October 2015. That is the date when the E3 / EU+3 (United States, United Kingdom, Germany, France, Russia, and China) and Iran began to make arrangements and preparations for the implementation of a “joint comprehensive plan of action” intended to provide for comprehensive lifting of all worldwide sanctions related to Iran’s nuclear program.
The lifting of sanctions by the EU and the United States will depend on the “implementation day” which will be when the International Atomic Energy Agency (IAEA) verifies that Iran has taken all of the key nuclear-related steps. With “implementation day,” it would be anticipated that there would be a (partly) lifting of the EU / U.S. nuclear-related sanctions against Iran. It is expected this date will be in the range of five months to 10 months. Until “implementation day,” all sanctions remain in place, and nothing changes as regards the legal requirements prohibiting exports to Iran.
The European Commission on 12 October 2015 adopted a regulation amending Council Regulation (EC) No 428/2009—the EU dual-use regulation. The updated EU dual-use list for export controls:
Read a November 2015 report prepared by the KPMG member firm in the Netherlands: Update Iran Sanctions – EU Dual-Use
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