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The U.S. Follows Through on Temporary Suspension of Sanctions, as Parties Continue to Negotiate Over Irans Nuclear Program

This week, the International Atomic Energy Agency (“IAEA”) verified that Iran has begun to meet its obligations to curtail nuclear development activities pursuant to the November 24, 2013 Joint Plan of Action agreement (“JPOA”) among Iran and the “P5+1” group of nations (the United States, Russia, China, France, the United Kingdom and Germany). In response, the United States immediately suspended targeted portions of its Iran sanctions programs, for a period of six months ending July 20, 2014. However, this rollback is subject to substantial exceptions and restrictions, ensuring that navigating the U.S. sanctions regime remains a complicated undertaking for even the most sophisticated and well-advised companies. Moreover, this limited and temporary easing of sanctions is taking place against the complex and uncertain backdrop of ongoing substantive negotiations over a comprehensive resolution of the dispute over Iran’s nuclear program. Those working for a diplomatic solution face obstacles (both political and practical) at every turn, presenting the prospect that, at the end of the six-month period, sanctions could not only be reinstated, but dramatically increased. We are advising our clients to tread carefully in considering whether to initiate or renew business activities with Iran in this uncertain climate.

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