On 16 January 2016, or "Implementation Day", legislation in the United States ("US") and European Union ("EU") came into effect, relaxing significantly the sanctions in place against Iran. This followed the issuing of a report by the International Atomic Energy Agency ("IAEA") to the UN Security Council, confirming that Iran had complied with its commitments under the Joint Comprehensive Plan of Action ("JCPOA").
The JCPOA foresaw the lifting of the EU's nuclear-related sanctions, and US secondary sanctions, upon the fulfilment by Iran of certain nuclear-related commitments, as verified by the IAEA. In recent weeks the projected timescales for this were shortened, and Implementation Day took place on 16 January 2016. Implementation Day has brought into effect very significant relief against the sanctions previously in effect against Iran. In our briefing, we set out the key changes to the sanctions regimes and consider the potential implications for business.
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