

persons to engage in such activities, and to permit imports of certain Iranian goods into the United States. entities that are owned or controlled by U.S. The United States has also agreed to license non-U.S. entities and persons to enter into certain transactions with Iran. However, the primary impact of sanctions relief under the JCPOA will be the expanded ability of non-U.S. Until such guidance is available, key implementation details are unknown. OFAC is expected to provide additional guidance on the JCPOA in the near future. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has announced that during this implementation period, sanctions relief currently in effect under the Joint Plan of Action (JPOA) will continue. sanctions is not expected to occur until at least early 2016. The United States retains the ability to revoke all sanctions relief if Iran fails to meet its nuclear obligations under the deal. Instead, the United States will begin to suspend its nuclear-related economic sanctions in a phased manner after verification of Iran’s implementation of the JCPOA by the International Atomic Energy Agency (IAEA). The United States has not lifted existing sanctions, nor does the JCPOA provide Iran with any immediate relief from current U.S. The plan builds on the parameters for a JCPOA previously announced on April 2, 2015.

On July 14, 2015, the United States and five other countries (collectively known as the P5+1 1) reached a Joint Comprehensive Plan of Action (JCPOA) with Iran under which Iran will limit its nuclear activities in exchange for a gradual lifting of international economic sanctions.
