Pillsbury Winthrop Shaw Pittman

US implements temporary changes to Iran sanctions under interim agreement

By Christopher R Wall, Stephan E Becker, Nancy A Fischer and Aaron R Hutman

On 20 January 2014, the US Treasury and state departments took steps to implement temporary and limited changes to US sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5+1 countries. Most US sanctions on Iran remain in place and will continue to be enforced. Between 20 January and 20 July 2014, non-US individuals and companies (unless US owned or controlled) will not face US sanctions enforcement if they engage in specified transactions relating to the (a) export of Iranian petrochemical products, (b) provision of goods and services for Iran’s auto industry, (c) sale of gold and precious metals to or from Iran and (d) provision of insurance and transport services associated with sales of Iranian oil to six specified countries. The US government also has adopted a favourable licensing policy in specified cases for the provision of goods and services to Iran’s civil aviation industry by US persons, US-owned/controlled foreign entities and non-US persons for the transfer of US goods or technology. The US also is taking steps to facilitate certain humanitarian and medical trade with Iran, payment of UN dues and support for Iranians studying abroad.

The P5+1 (the US, the UK, France, China, Russia and Germany) reached an interim agreement (the ‘joint plan of action’) with Iran on 24 November 2013 aimed at limiting Iran’s uranium enrichment and potential for nuclear weapons development. On 20 January 2014, the International Atomic Energy Agency verified that Iran had met its initial obligations under the joint plan of action, leading to implementation of US and EU sanctions commitments. These sanctions changes are temporary and will be maintained only during negotiations and while Iran continues to meet its reciprocal obligations. The interim agreement is scheduled to last for six months until 20 July 2014, with the possibility of renewal, and the parties are expected to negotiate toward a potential final agreement during that time period…

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