Today, the International Atomic Energy Agency (“IAEA”) announced that Iran has met the first round of its nuclear-related commitments under the Joint Comprehensive Plan of Action (“JCPOA”).  As Steptoe explained when the JCPOA was agreed to between Iran and the P5+1 countries in July 2015, Iran would not receive any sanctions relief until “Implementation Day,” the day on which the IAEA reached this conclusion.

Now that the IAEA has made its announcement, today is Implementation Day.  Iran is now able to access billions of dollars of its funds that have been frozen in foreign banks, and the US has announced details regarding the implementation of sanctions relief, including the suspension of many secondary sanctions targeting non-US persons and a new licensing policy to allow foreign subsidiaries of US companies to conduct JCPOA-consistent business.  Importantly, we note that secondary sanctions related to Iran’s human rights record, proliferation of weapons of mass destruction, and support for terrorism remain in place, as well as most primary sanctions restricting US persons’ activity with Iran.

Furthermore, the European Union has issued sanctions relief pursuant to the JCPOA.