Summary

On 16 January 2015, the P5+1 (China, France, Germany, Russia, the United Kingdom, and the United States), the European Union, and Iran announced the next step – Implementation Day – under the political agreement over Iran’s nuclear program known as the Joint Comprehensive Plan of Action (JCPOA).

As expected, the implementation of the JCPOA generally did not change, for example: the primary U.S. sanctions that apply to U.S. companies; U.S. export controls on U.S. products, parts, software, technology, or services or foreign made products incorporating controlled U.S. content; transactions involving U.S. dollars clearing through the United States; reporting obligations for issuers under U.S. securities laws; reporting and investment restrictions under U.S. state and local laws; and U.S. anti-money-laundering laws and regulations. While nuclear-related “secondary” U.S. sanctions targeting non-U.S. companies were lifted, there remain approximately over 200 Iranian Specially Designated Nationals (SDNs) with whom activities could still create exposure under U.S. secondary sanctions, even if the activity has no U.S. nexus. There are certain opportunities for U.S. companies in areas such as the Iranian-origin food, civil aviation and business services sectors as well as for non-U.S. subsidiaries meeting specific criteria.  
 
The EU has lifted most of its trade restrictions with Iran on Implementation Day. In particular, all financial transfers to and from Iran are now permitted, except with six listed Iranian banks and other listed parties which remain subject to asset-freezing measures. Trade with Iran and non-listed Iranian persons is allowed, with the following exceptions:

  • complete embargo remains on the export to Iran of:
    • goods and technology listed under the EU's Common Military List;
    • missile technology;
    • equipment for internal repression; and
    • equipment for monitoring communications.
  • Prior authorisations remain a requirement for the export to Iran of:
    • Nuclear Suppliers Group goods and technology;
    • other listed dual-use goods and technology that could contribute to reprocessing, enrichment-related, heavy water-related or other activities inconsistent with the JCPOA;
    • graphite and raw or semi-finished metals; and
    • Enterprise Resource Planning software, designed specifically for use in nuclear and military industries.
  • Asset-freezing measures remain on persons and entities under both the EU Iran nuclear-proliferation sanctions, and the EU sanctions in relation to Iran's human rights violations.

Given these exceptions to the lifting of EU sanctions, companies should continue to conduct EU-specific due diligence on transactions with Iran.  

Introduction

On 14 July 2015, the P5+1 reached a political agreement over Iran’s nuclear program known as the JCPOA.  On October 18, 2015, the JCPOA went into effect (with no lifting of any sanctions) and participants began taking steps necessary to implement their JCPOA commitments. 
 
On 16 January 2016, the International Atomic Energy Agency (“IAEA”) verified that Iran has implemented its key nuclear-related measures as described in the JCPOA. The IAEA’s verification marked the occurrence of Implementation Day under the implementation plan agreed to in the JCPOA. As a result, the United States and European Union began lifting nuclear-related sanctions on Iran. The U.S. and Iran also announced a prisoner swap.
 
From Iran’s perspective, the most immediate impact of Implementation Day will be access to tens of billions of dollars in overseas foreign reserves that were held in restricted accounts in certain third countries permitted to buy Iranian oil pursuant to temporary exemptions — a little over US$50 billion, according to the U.S. Treasury Department. 
 
The sanctions relief on Implementation Day lifted most EU trade restrictions with Iran, and many U.S. restrictions on non-U.S. companies.  Some very limited sanctions relief also took effect for U.S. companies, though the vast majority of restrictions on activities by U.S. companies remain in place. In the longer term, the sanctions relief offers many opportunities for non-U.S. companies, which may engage in a variety of transactions that were previously the subject of secondary sanction under U.S. law. However, caution is still warranted, as prohibitions on dealings with a number of Iranian entities remain in effect, and companies doing business with these entities remain subject to potential designation under U.S. secondary sanctions.

U.S. Sanctions Relief

On Implementation Day, the United States lifted the nuclear-related “secondary sanctions” described in the JCPOA. Secondary sanctions generally are directed toward non-U.S. persons for specified conduct involving Iran that occurs entirely outside of U.S. jurisdiction. Primary sanctions are restrictions on activities by U.S. persons, wherever located, or non-U.S. entities owned or controlled by U.S. persons, or activities involving USD funds transfers or goods/software/technology subject to U.S. law. 

While the primary sanctions relief is limited, leaving in place most restrictions on U.S. persons, U.S. companies, the use of the U.S. financial system, and the export of U.S.-origin goods to Iran, the secondary sanctions relief is far broader, and eliminates many of the restrictions on non-U.S. companies. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a narrow general license for certain activities by non-U.S. subsidiaries of U.S. companies, as well as a general license authorizing the importation into the U.S. of Iranian foodstuffs (specifically including but not limited to pistachios and caviar) and carpets.  In addition, OFAC has announced a continued favorable licensing policy for certain activities related to civil commercial aviation.
 
On Implementation Day, President Obama issued an Executive Order terminating certain prior Executive Orders pertaining to secondary sanctions.  The remainder of secondary sanctions relief is being implemented through waivers. These waivers will eventually be replaced by termination of the underlying measures on Transition Day, which occurs eight years from the adoption of the JCPOA or after the IAEA certifies that all nuclear material in Iran remains in peaceful activities, whichever occurs earlier. In addition, a number of Iranian entities specified in the JCPOA were removed from OFAC’s SDN List, so non-U.S. persons dealing with such removed entities will not face exposure under residual secondary U.S. sanctions. (We note, however, that a number of those entities removed from the SDN list remains subject to primary OFAC sanctions as they are owned/controlled by the Government of Iran, and are included on a separate list that OFAC is maintaining for such purpose).
 
Non-U.S. companies are still subject to secondary sanctions for engaging in activities involving Iranian entities that remain on the SDN List. These entities have been designated in connection with Iran’s proliferation of WMD or their means of delivery or Iran’s support for international terrorism. Some of these entities include Bank Saderat, Bank Sepah, Mahan Air, Meraj Air, and Tidewater.  
 
Specifically, on Implementation Day, the United States lifted the following secondary sanctions on non-U.S. persons (when the activity does not involve a U.S. nexus, including no U.S. dollar transfers):

  • Financial and banking-related sanctions: Non-U.S. financial institutions will no longer be subject to secondary sanctions for transactions with, among others, the Central Bank of Iran (CBI), the National Iranian Oil Company (NIOC), the Naftiran Intertrade Company (NICO), the National Iranian Tanker Company (NITC), and certain other entities that were removed from the SDN List. Transactions involving the Iranian rial and Iranian sovereign debt, or the provision of specialized financial messaging services to the CBI, are also no longer subject to secondary sanctions.  However, transactions with certain SDNs, including entities blocked in connection with Iran’s proliferation of weapons of mass destruction (WMD), remain prohibited.
  • Sanctions on the provision of underwriting services, insurance, or re-insurance: Non-U.S. companies are no longer subject to secondary sanctions for providing underwriting services, insurance, or re-insurance in connection with activities consistent with the JCPOA.  Specifically, these include activities in the energy, shipping, and ship-building sectors of Iran, for NIOC or NITC, or for vessels that transport crude oil, natural gas, liquefied natural gas, petroleum and petrochemical products to or from Iran. U.S. (re)insurers, however, remain subject to primary U.S. sanctions and generally cannot provide cover to non-U.S. companies who are taking advantage of this easing of secondary U.S. sanctions.
  • Sanctions on Iran’s energy and petrochemical sectors: The United States has ceased efforts to reduce Iran’s crude oil sales, including limitations on the quantities of Iranian crude oil sold and the nations that can purchase Iranian crude oil. Non-U.S. companies are no longer subject to secondary sanctions for investment activities in the energy sector, including through participation in joint ventures or the provision of goods, services, information, technology and technical expertise and support for Iran’s oil, gas, and petrochemical sectors. Likewise, the purchase, acquisition, sale, transportation, or marketing of petroleum, petrochemical products and natural gas from Iran, and the export, sale, or provision to Iran of refined petroleum products and petrochemical products are no longer sanctionable activities, nor are transactions with Iran’s energy sector, including NIOC, NICO, and NITC.  
  • Sanctions on transactions with Iran’s shipping and shipbuilding sectors and port operators: Non-U.S. companies are no longer subject to secondary sanctions for engaging in transactions with Iran’s shipping and shipbuilding sectors, including with NITC, the Islamic Republic of Iran Shipping Line (“IRISL”), and South Shipping Line. Similarly, based on OFAC’s determination that Tidewater Middle East Co. (“Tidewater”) is no longer the port operator of Bandar Abbas, secondary sanctions will no longer apply solely on the basis of engaging in transactions with or conducting trade through Bandar Abbas. 
  • Sanctions on the sale, supply, or transfer of goods and services used in connection with Iran’s automotive sector: Non-U.S. companies are no longer subject to secondary sanctions for engaging in the sale, supply, or transfer of goods and services to be used in connection with Iran’s automotive sector.

The impact on primary U.S. sanctions under the Iranian Transactions and Sanctions Regulations (ITSR) is very limited. This relief includes a narrow general license for certain activities of non-U.S. subsidiaries of U.S. companies, a general license for the importation of Iranian-origin foodstuffs and carpets into the U.S, a favorable licensing policy for certain activities pertaining to civil aviation and favorable guidance for certain providers of authorized business services:

  • Non-U.S. Subsidiaries of U.S. Companies: OFAC has issued Iran General License H (GL H), authorizing U.S.-owned or controlled foreign entities to engage in certain transactions with Iran that would otherwise be prohibited by the ITSR. GL H defines an entity as owned or controlled by a U.S. person “if the U.S. person: (i) holds a 50 percent or greater equity interest by vote or value in the entity; (ii) holds a majority of seats on the board of directors of the entity; or (iii) otherwise controls the actions, policies, or personnel decisions of the entity.” U.S. persons are authorized to engage in activities related to the establishment or alteration of operating policies and procedures of a U.S. entity or U.S.-owned or controlled foreign entity to the extent necessary to allow the U.S.-owned or controlled foreign entity to engage in activities authorized by the general license. GL H authorizes U.S. persons, including employees and outside legal counsel and consultants, to provide training, advice, and counseling on the new or revised operating policies and procedures, provided that these services are not provided to facilitate transactions in violation of U.S. law. However, this does not allow U.S. persons to be involved in the Iran-related day-to-day operations of a U.S.-owned or controlled foreign entity, nor does it allow U.S. persons to approve, facilitate, finance, or guarantee Iran-related transactions by such foreign entities. 
  • Finally, U.S. persons may make available to a U.S.-owned or controlled foreign entity automated (passive) and globally integrated computer, accounting, email, telecommunications, or other business support systems, platforms, databases, application, or servers necessary to store, collect, transmit, generate, or otherwise process documents or information related to Iran-related transactions. An activity is not considered “automatic” if it would require human intervention to be completed, and such activities are still prohibited to U.S. persons (e.g., a U.S. person could not perform data entry or internal processing for the creation of a customer record for an Iran-related transaction by a U.S.-owned or controlled foreign entity).
    • Authorized business service providers: GL H authorizes U.S. persons to “make available” any automated and globally integrated computer, accounting, email, telecommunications, or other business support system, platform, database, application, or server necessary to store, collect, transmit, generate, or otherwise process documents or information related to transactions by foreign entities they own or control that are authorized by GL H (hereinafter referred to as Authorized Business Support Systems). The authorization in GL H permits U.S. parent companies to make available to foreign entities they own or control Authorized Business Support Systems that are owned and/or operated for the U.S. parent company on a contract basis by one or more third-party service providers. Likewise, U.S. person third-party service providers are authorized to make available to a U.S.-owned or -controlled foreign entity Authorized Business Support Systems that they provide to the U.S. parent company on a contract basis but without providing transaction-specific support for Iran-related activities.
       
  • Civil Aviation: OFAC has issued a statement of licensing policy establishing a favorable licensing policy for requests for specific authorization to engage in transactions for the (i) export, re-export, sale, lease or transfer to Iran of commercial passenger aircraft for exclusively civil aviation end-use; (ii) export, re-export, sale, lease or transfer to Iran of spare parts and components for commercial passenger aircraft; and (iii) provision of associated services, including warranty, maintenance, and repair services and safety-related inspections, for all the foregoing, provided that licensed items and services are used exclusively for commercial passenger aviation. However, if the United States determines that licensed aircraft, goods, or services have been used for purposes other than exclusively for commercial passenger aviation, or have been re-sold or re-transferred to persons on the SDN List, the United States would view this as grounds to cease performing” its civil aviation commitments in the JCPOA.
  • Imports of Food: OFAC has issued a regulatory amendment to the ITSR, which will be effective upon publication in the Federal Register, authorizing the importation into the U.S. of Iranian-origin carpets and foodstuffs, including caviar and pistachios. The new general license will authorize imports of Iranian-origin good into the U.S. (from Iran or a third country), as well as dealings in Iranian-origin food (even if not being imported into the U.S.). 

In addition to the lifting of the nuclear-related secondary sanctions set out above, on Implementation Day, the United States removed over 400 individuals and entities from OFAC’s SDN List, the Foreign Sanctions Evaders List (FSE List), and/or the Non-SDN Iran Sanctions Act List (NS-ISA List).  Beginning on Implementation Day, non-U.S. persons will no longer be subject to secondary sanctions for conducting transactions with any of the more than 400 individuals and entities set out in the JCPOA, including the CBI and other specified Iranian financial institutions.  However, many of those 400 entries remain subject to restrictions on dealings by U.S. persons under the ITSR as such entities are owned/controlled by the Government of Iran, meaning that its assets and property interests remain subject to blocking (freezing) if they are in the United States or within the possession of a U.S. person.
 
Nevertheless, secondary sanctions continue to apply to non-U.S. persons for conducting transactions with any of the more than 200 Iranian or Iran-related individuals and entities that remain or are placed on the SDN List. 

U.S. Sanctions Still in Force

Despite the sanctions relief described above, a number of U.S. sanctions authorities with respect to Iran remain in place after Implementation Day, including:

  1. Primary U.S. Sanctions: The U.S. domestic trade embargo on Iran remains in place.  Even after Implementation Day, with limited exceptions, U.S. persons wherever located – including U.S. companies and their non-U.S. branches – continue to be broadly prohibited from engaging in transactions or dealings with Iran or its government.  In addition, the Government of Iran and Iranian financial institutions remain persons whose property and interests in property are blocked, and U.S. persons continue to be broadly prohibited from engaging in transactions or dealings with the Government of Iran and Iranian financial institutions, with the exception of transactions that are exempt from regulation or authorized by OFAC (As noted above, although a number of entries were removed from the SDN list, they are maintained on a separate OFAC list as being subject to restrictions that apply to the Government of Iran).  Unless an exemption or express OFAC authorization applies, U.S. persons continue to have an obligation to block the property and interests in property of all individuals and entities that meet the definition of the Government of Iran or an Iranian financial institution, regardless of whether or not the individual or entity has been identified by OFAC. In addition, non-U.S. persons continue to be prohibited from knowingly engaging in conduct that seeks to evade U.S. restrictions on transactions or dealings with Iran or that causes the export of goods or services from the United States to Iran.
  2. U.S. export controls: All licensing requirements and prohibitions under the ITSR and the U.S. Export Administration Regulations (EAR) continue to apply to exports and re-exports by U.S. persons or from the United States to Iran or the Government of Iran, as well as re-exports by non-U.S. persons of items with 10 percent or more U.S.-controlled content to Iran or the Government of Iran, if undertaken with knowledge or reason to know that the re-exportation is intended specifically for Iran or the Government of Iran.
  3. State/Local Laws: A number of U.S. states have divestment and procurement bans on companies that have dealings with Iran.  These are not impacted by the JCPOA in general, or Implementation Day in particular.
  4. U.S. Securities Reporting: Sec. 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 requires U.S. issuers to report activities involving certain types of transactions in or with Iran, including but not limited to activities with certain entities in Iran or on the SDN List to the U.S. Securities and Exchange Commission (SEC).  The reporting obligation is not extinguished by the recent changes to U.S. sanctions and companies should continue to assess whether Iran-related activities need to be reported in quarterly and annual reports due to the SEC.
  5. Designation authorities: In addition, after Implementation Day, the United States retains a number of authorities to counter Iran’s other activities, including
    • Support for terrorism;
    • Iran’s human rights abuses;
    • Proliferation of WMD and their means of delivery, including ballistic missiles; and
    • Support for persons involved in human rights abuses in Syria or for the Government of Syria; and
  6. Support for persons threatening the peace, security, or stability of Yemen.Secondary Sanctions targeting dealings by non-U.S. persons with Iran-related persons remaining on the SDN List after Implementation Day or involving trade in certain materials involving Iran:  After Implementation Day, secondary sanctions continue to attach to significant transactions with:  (1) Iranian persons that are on the SDN List; (2) the Islamic Revolutionary Guard Corps (IRGC) and its designated agents or affiliates; (3) any other person on the SDN List designated in connection with Iran’s proliferation of weapons of mass destruction (“WMD”) or their means of delivery or Iran’s support for international terrorism; and (4) Iran’s human rights abuses and censorship activities.  

OFAC made clear that it will continue to exercise these designation authorities when, on January 17, 2016, the day after Implementation Day, it designated a number of Iranian and third-country entities for supporting Iran’s ballistic missile procurement activities.

EU Sanctions Relief

On Implementation Day, the EU adopted Council Decision 2016/37, which brought into force Council Decision 2015/1863 and published a notice (OJ 2016/C 15 I/01) confirming the entry into force of Council Regulation (EU) 2015/1861 and Council Implementing Regulation (EU) 2015/1862.  By virtue of these legislative acts, the EU has lifted with immediate effect most of its nuclear-related sanctions, as described in the JCPOA. 
 
The sanctions lifted include the following sectors:

  • Financial, and banking activities: The broad prohibition on financial transfers to or from Iran and Iranian persons or entities has been lifted and so the reporting and authorisation requirements no longer apply.  Some Iranian banks have been delisted (such as Bank Mellat, Bank Melli Iran, Bank Tejarat and the Central Bank of Iran),  but six Iranian banks remain listed (see "EU Sanctions Still In Force" below). Delisted Iranian banks can reconnect to SWIFT automatically, once SWIFT's normal connection processes have been completed. Banking activities, such as the establishment of new correspondent banking relationships and the opening of branches, subsidiaries or representative offices of non-listed Iranian banks in Member States are permitted.
  • Insurance: The provision of underwriting services, insurance, or re-insurance to non-listed Iranian persons or entities is permitted.
  • Oil, gas and petrochemical sectors: The import, purchase, swap and transport of crude oil and petroleum products, gas and petrochemical products from non-listed Iranian persons is allowed as of Implementation Day. Restrictions on goods and technology for use in the oil, gas and petrochemical sectors no longer apply, and technical assistance (including training) and investment in those sectors is permitted.
  • Shipping, shipbuilding and transport sectors: Ship-building and construction, vessels for oil transport and storage, bunkering and ship supply services, as well as provision of classification services to non-listed Iranian persons are now permitted.
  • Gold, other precious metals, base metals, banknotes and coinage
  • Software: Previous restrictions on Enterprise Resource Planning software only remain where that software is designed specifically for use in nuclear and military industries.
  • Associated services for each of the categories above

EU Sanctions Still In Force

While the majority of EU sanctions are lifted, the following restrictions remain in place with respect to Iran:

  1. Nuclear-related sanctions: An arms embargo covering all goods on the EU Common Military List, and missile technology sanctions covering all goods and technology contained in the Missile Technology Control Regime list. Six Iranian banks – Ansar Bank, Bank Saderat Iran and Bank Saderat plc, Mehr Bank, Bank Sepah and Bank Sepah International – continue to be listed. These banks remain subject to asset-freezing measures and prohibition on the provision of specialised financial messaging services (SWIFT). Certain persons and entities also remain listed and continue to be subject to asset freezing measures.
  2. Nuclear-related authorisations: Certain nuclear sector transfers and activities remain subject to prior authorisation. These include the goods and technology listed in the Nuclear Suppliers Group, as well as other dual-use goods and technology that could contribute to reprocessing, enrichment-related, heavy water-related or other activities inconsistent with the JCPOA. Previous prohibitions on the sale, supply, export or transfer of listed metals and graphite have now been downgraded to requirements for prior authorisation from EU Member States. The restriction on the provision of Enterprise Resource Planning software for use other than nuclear and military industries is lifted. However, Enterprise Resource Planning software for use in nuclear and military industries is subject to prior authorisation.   Particular caution should be paid to the sectors known to be controlled domestically by the Islamic Revolutionary Guard Corps (IRGC), which remains a listed entity, as well as 15 entities owned, controlled or acting on behalf of the IRGC which remain also listed. We note that the IRGC is heavily involved throughout the Iranian economy, and caution in carrying out due diligence when screening parties remains paramount.
  3. Sanctions related to Iran human-rights violations: All the restrictions imposed in response to the Iranian government's record of human rights violations, set out in Council Decision 2011/235 and Council Regulation (EU) No 359/2011, both last amended on 7 April 2015, remain in force. These are a complete ban on the export of equipment which may be used for internal repression, or monitoring telecommunications. Asset-freezing measures remain on 84 persons and 1 entity in relation to their involvement in human rights violations.

Reasons for Caution

Even after Implementation Day, the U.S. embargo generally remains in place. With primary U.S. sanctions still in effect, U.S. persons, including companies, remain broadly prohibited from engaging in transactions with Iran, as well as with Iranian individuals and entities, such as financial institutions. For example, Treasury Secretary Jack Lew has testified to Congress that Iranian banks will not be able to clear U.S. dollar payments through New York (even when a sender and a recipient are outside the United States – i.e.,the “U-turn” transactions that were previously authorized by general license until 2008), hold correspondent account relationships with U.S. financial institutions, or enter into financing arrangements with U.S. banks.
 
These general prohibitions on U.S. persons include: investment in Iran; importing Iranian-origin goods or services; and exporting goods or services to Iran, including clearing U.S. dollars.  The Government of Iran (GOI) and Iranian financial institutions — including any property in which they have an interest — remain blocked by the United States.  Additionally, U.S. export controls continue to apply to controlled U.S.-origin goods and technology located anywhere in the world.
 
As noted above, the U.S. will also continue to impose secondary sanctions. The United States retains secondary sanctions authorities targeting third parties for dealings with Iranian persons/entities that remain designated on OFAC’s SDN List that have been designated under terrorism, counter-proliferation, missile, and human rights authorities. Although a large number of Iranian SDNs have been removed from the SDN List, a significant number remain, and non-U.S. persons dealing in the future with such Iranian SDNs will continue to face possible exposure under secondary U.S. sanctions. OFAC has emphasized in its Implementation Day guidance that persons contemplating transactions with Iran remain obligated to carry out due diligence to ensure that the transactions do not involve parties with whom dealings are still potentially sanctionable.
 
In practice, persons transacting with or supporting individuals or entities sanctioned in connection with Iran’s support for terrorism or development of WMD and missiles — as well as any Iranian individual or entity who remains on the SDN List — risk being cut off from the U.S. financial system or facing even more dire restrictions, such as asset freezes. This includes foreign financial institutions, which would risk losing their correspondent accounts with U.S. banks. Sanctions will also continue to apply to persons who provide Iran with specified weapons, dual use goods and related technologies. 
 
Finally, the EU and the U.S. have indicated that the sanctions currently subject to relief could be "snapback" in the event of Iranian non-compliance with the terms of JCPOA. OFAC will not grandfather contracts entered into prior to snapback  but it may issue limited wind-down authorization allowing companies to terminate their business activities in Iran. By contrast, the EU will contemplate a grace period in the event of snapback of the sanctions currently subject to relief.
 
Conclusion
 
Despite the steps taken by the U.S. and EU described above, it is critical to remember that the U.S. embargo broadly remains in place, meaning that U.S. persons, including U.S. banks, will still be prohibited from nearly all dealings with Iranian entities. Likewise, while many U.S. secondary sanctions have been lifted, dealings with a large number of Iranian entities remain prohibited, and non-U.S. companies must continue to exercise caution and carry out due diligence before entering into Iran-related transactions.
 
The EU has made it clear that it is the responsibility of every individual or entity within the EU, and EU nationals anywhere in the world, to continue to conduct due diligence checks to ensure that they are not making funds or economic resources available to listed persons or entities. In particular, the continued listing of the IRGC means that care should be taken as to the screening of counterparties' corporate structures where they may be involved. Furthermore, the continued U.S. sanctions will still need to be taken into account for the large majority of transactions, even where these are ostensibly EU-only.  Steps will also need to be taken to reduce money-laundering and bribery and corruption risks.  This highlights the continued need for caution in relation to dealings with Iran on the EU side.

APPENDIX 1 (U.S. Changes)
 
On Implementation Day, OFAC issued several documents, effective January 16, 2015. Specifically, OFAC posted to its website:

 
In addition, OFAC has submitted for publication in the Federal Register final rule adding a general license relating to the importation into the United States of Iranian-origin carpets and foodstuffs, including pistachios and caviar; this general license will be effective upon publication in the Federal Register.
 
OFAC has also published additional information regarding actions to give effect to other JCPOA commitments, including removals from the:

In addition, OFAC has made available on its website a list of persons identified as blocked solely pursuant to Executive Order 13599 (“E.O. 13599 List”), which consists of persons that OFAC previously identified as meeting the definition of the Government of Iran or an Iranian financial institution.
 
On Implementation Day, President Obama also issued an Executive Order terminating a number of prior Executive Orders pertaining to secondary sanctions.
 
Implementation Day also marks the close of the Joint Plan of Action of November 24, 2013, as extended (JPOA), including the provision of sanctions relief pursuant to the JPOA.
 
Effective Implementation Day, all specific licenses that: (1) were issued pursuant to OFAC’s Second Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry, and (2) have an expiration date on or before July 14, 2015, are authorized to remain in effect according to their terms until May 31, 2016.
 
APPENDIX 2 (EU Changes)
 
On Implementation Day, the EU published in the Official Journal Council Decision 2016/37, which brought into force Council Decision 2015/1863 of 18 October 2015:
 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2016:011I:TOC   
 
The EU also published in the Official Journal, a notice explaining the coming into force of Council Regulation (EU) 2015/1861 and Council Implementing Regulation (EU) 2015/1862, both also of 18 October 2015.
 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C:2016:015I:TOC 
 
The EU has released a detailed overview of the changes in its "EU Information Note on EU sanctions to be lifted under the JCPOA":
 
http://eeas.europa.eu/top_stories/pdf/iran_implementation/information_note_eu_sanctions_jcpoa_en.pdf