Iran Sanctions: Where Are We and What’s Next?

As has been widely reported, on April 2, 2015, the P5+1 powers, the European Union, and Iran announced a framework agreement for a “Joint Comprehensive Plan of Action” pursuant to which nuclear-related sanctions against Iran would be eased in return for restrictions on Iranian nuclear programs. Our alert memorandum analyzes the sanctions-related aspects of the framework agreement. The key takeaways are as follows:

• Agreement has been reached on the basic outlines of a deal, and the parties appear to be committed to proceeding. However, the deal is not yet final, and work remains to be done. For the moment, the sanctions regime remains unchanged.
• The agreement is skeletal and preliminary, and key details regarding the timing and scope of sanctions relief are already in dispute between Iran and the United States. It remains possible that the agreement will collapse or that negotiations will extend beyond the nominal June 30 deadline.
• The broad outline of the deal appears to be suspension of most U.S. secondary sanctions against Iran (though the basic prohibition on transactions with Iran within U.S. jurisdiction will remain) and a roll-back of the European sanctions regime to a more limited pre-2010 level.
• Even if agreement is reached, domestic implementation remains a challenge in the United States, and the precise scope of U.S. sanctions relief – and the degree of divergence between U.S. and EU sanctions – is not entirely clear.

Please feel free to raise any question or concern you may have with any of your regular contacts at the Firm, or with Paul Marquardt in our Washington office, Till Müller-Ibold in our Brussels office, or Sunil Gadhia in our London office.