Jan. 16, 2016 marked “Implementation Day” of the Iran Joint Comprehensive Plan of Action (JCPOA), as the U.S. initiated the removal of its nuclear-related sanctions against Iran and the EU removed the majority of its existing Iran-related sanctions. The final precondition to Implementation Day was met when the International Atomic Energy Agency (IAEA) issued a report verifying that Iran has fulfilled its initial commitments under the JCPOA.
Importantly, while Implementation Day has brought the lifting of many EU sanctions against Iran, U.S. sanctions relief remains largely limited to the lifting of U.S. nuclear-related sanctions only, leaving in place the comprehensive U.S. embargo against Iran. With the exception of certain transactions related to commercial aircraft sales to Iran and the import of Iranian foodstuffs and carpets, U.S. sanctions relief under the JCPOA is restricted to the lifting of sanctions directed at non-U.S. persons only. U.S. individuals and entities will remain prohibited from engaging in most transactions with Iran, whether direct or indirect, for the foreseeable future.