The EU announced on 14 January that it would prolong its existing suspension of certain (limited) sanctions on Iran until 28 January 2016 to allow time for implementation of the Joint Comprehensive Plan of Action (the "JCPOA"). Council Decision (CFSP) 2016/35, Council Decision (CFSP) 2016/36 (both amending Decision 2010/413 CFSP), and Council Regulation (EU) 2016/31 (amending Regulation (EU) 267/2012) were published in the Official Journal on 15 January to give effect to this extension.
The EU originally suspended a limited number of its restrictive measures against Iran following the November 2013 agreement of the Joint Plan of Action ("JPOA") (see our previous briefing for further details of the suspensions). Following the agreement of the JCPOA in July 2015, this suspension was extended until 14 January 2016.
The JCPOA will enter into effect on "Implementation Day": the point at which the International Atomic Energy Agency verifies that Iran has satisfied its nuclear-related obligations and at which certain EU and US sanctions are to be relaxed. Recent press reports have indicated that, although no fixed day has been set for Implementation Day, it is expected to occur in the coming days or weeks. The short length of the EU's extension of the current JPOA suspensions is consistent with this expectation.
We will publish updates on any further developments as Implementation Day approaches.
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