U.S. Provides Limited Relief from Secondary Sanctions Against Iran

On January 20, the United States authorities released guidance implementing the “P5+1” agreement providing limited, temporary sanctions relief to Iran, and they have since clarified the scope of the relief in public statements. The changes are quite modest and do not affect U.S. companies or their controlled affiliates. The primary change is that non-U.S. companies have a narrow window (until July 20) within which to complete certain transactions outside U.S. jurisdiction with the Iranian automotive or petrochemical sectors, or dealings in precious metals, without risking the imposition of U.S. secondary sanctions. The below memo provides further detail.