The EU has amended its Iran sanctions regime to enable Iran carry out actions needed to meet its commitments under the Iran nuclear sanctions deal, memorialised in the June 2015 Joint Comprehensive Plan of Action (JCPOA) (see the Debevoise Client Update of 17 July 2015). These changes follow the UN Security Council’s unanimous decision to adopt Resolution 2231, endorsing the JCPOA and providing for its implementation (see Issue 41 of the Sanctions Alert).

Pursuant to Council Regulation (EU) 2015/1327 amending Council Regulation (EU) 267/2012 and Council Decision (CFSP) 2015/1336 amending Council Decision 2010/413/CFSP, the EU now permits the provision of goods and services to Iran to enable Iran to meet certain terms of the JCPOA. These terms include modifying its Fordow nuclear facility, modernising the Arak nuclear facility and exporting Iran’s enriched uranium above the permitted limit in exchange for natural uranium. The amendments further provide that EU Member States may now authorise, on a case-by-case basis, transfers and activities in so far as they are necessary for the execution of certain nuclear related actions in the JCPOA, required to prepare for implementation of the JCPOA more broadly, or determined by the UN Sanctions Committee to be consistent with the objectives of Resolution 2231.