Q&A - JCPOA of 14 July 2015
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- Lenard Oliver
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1 Iran sanctions lift On July 14, 2015, the EU, U.S., Russia, China, France, UK and Germany agreed with Iran on a Joint Comprehensive Plan of Action (JCPOA)
2 Q&A - JCPOA of 14 July 2015 As an exporter, what do I need to consider in general when doing business with Iran? Exporters need to know: with whom they are doing business (are there any sanctioned persons or entities involved in the transaction?); what is the nature of the their export (is their item classified as dual-use or military?); what will be the end-use of their item in Iran (will their item be used in prohibited end-uses?); how should they settle their financial transaction (since not all banks are keen to facilitate transactions with Iranian entities). Can I do business without any restrictions with Iran right now? All sanctions remain in place until they are formally lifted. In the most positive scenario, businesses can benefit from the JCPOA sanctions relief at implementation day in the first quarter of This does not implicate that no business can be conducted with Iran at this moment, but this needs to be determined carefully on a case by case basis. Will all sanctions against Iran be relieved? Nuclear related sanctions will be relieved, which means that non-nuclear related sanctions such as those for human rights abuse will remain active. Hence, Iran remains a high risk destination and so the exporters need do diligently investigate all elements of their intended transaction. Will I benefit from the Iran sanction relief? Please go to the next page to know which U.S. and EU sanctions will be relieved. As an Exported, how can I prepare myself if I want to do business with Iran? Exporters can: identify the nature of their goods (check if you need a license); assess whether their transaction is prohibited/restricted by non-nuclear related sanctions against Iran; screen the parties involved in their transaction; investigate the end-use of their product; investigate possible subjection of U.S. jurisdiction in their transaction; design their financial settlement route. Will my bank facilitate my transactions with Iran when sanctions are formally relieved? Even though your future transaction may be legitimate under the Iran sanctions relief, banks still may be hesitant to facilitate your transaction. The EU and U.S. sanction relief under the JCPOA are not similar. What does this mean for me? You should check which jurisdiction(s) is/are applicable to you. Do you export U.S. origin products or technology? Do your products contain any U.S. origin components or technology? Are you a subsidiary of a U.S. company? Do you settle transactions in U.S. dollars? In these cases you might be subjected to the more strict U.S. sanctions jurisdictions.
3 Which sanctions will be relieved? U.S. Sanctions relief - Removal of secondary sanctions applied to non-u.s. persons outside of the U.S. in the financial and banking, energy/extractive, petroleum/petrochemical, gold and precious metals, raw and semi-finished metals, automotive, shipping and port, insurance and certain other sectors. Current sanctions relating to Iran generally will remain for U.S. persons - Issue of licenses to allow the sale of commercial passenger aircraft to Iran, as well as spare parts and related maintenance and repair services. U.S. export controls for dual use and military items generally will remain in place for Iran, including re-export of such items to Iran by parties outside the U.S. - Issue of licenses to allow non-u.s. subsidiaries of U.S. companies to engage in activities with Iran that are consistent with this JCPOA. The precise scope of activities that will be licensed is unclear. Restrictions will remain for non-u.s. companies owned or controlled by U.S. persons - Allow imports into the U.S. of Iranian-origin carpets and foodstuffs (e.g., caviar and pistachios) - Removal of a number of Iranian entities from the List of Specially Designated Nationals, which among other things would make them eligible to be approved for transactions under U.S. licenses. EU Sanctions relief - Transfers of funds between EU persons and entities, including FI s, and Iranian persons and entities, including FI s - Banking activities, including the establishment of new correspondent banking relationships and opening of new branches and subsidiaries of Iranian banks in the territories of EU Member States - Provision of insurance and re-insurance - Supply of specialized financial messaging services, including SWIFT, for certain persons and entities, including the Central Bank of Iran and Iranian financial institutions. - Financial support for trade with Iran (export credit, guarantees or insurance) - Commitments for grants, financial assistance and concessional loans to the Government of Iran - Transactions in public or public-guaranteed bonds - Import and transport of Iranian oil, petroleum products, gas and petrochemical products - Export of key equipment or technology for the oil, gas and petrochemical sectors - Investment in the oil, gas and petrochemical sectors - Export of key naval equipment and technology - Design and construction of cargo vessels and oil tankers - Provision of flagging and classification services - Access to EU airports of Iranian cargo flights - Export of gold, precious metals and diamonds - Delivery of Iranian banknotes and coinage - Export of graphite, raw or semi-finished metals such as aluminum and steel, and export of software for integrating industrial processes - Designation of persons, entities and bodies (asset freeze and visa ban) set out in the JCPOA - Associated services for each of the categories above
4 Time line - Iran sanctions lift 14-Jul-15 July /Aug, 2015 Mid-Sept Oct Dec.15, 2015 Dec.15, 2015 early 2016 Dec.15, 2015 early 2016 Time line Finalization Day of JCPOA UN Security Council resolution consistent with JCPOA (provisional and pending later IAEA verification) U.S. Congress votes to approve/reject (implementation of deal if no action or Presidential veto and override vote if rejection Adoption Day (90 days after UN resolution) U.S. and EU to take advance actions to direct sanctions relief after IAEA verification) IAEA Director General s final assessment of past military dimensions of Iran s nuclear program IAEA verifies Iran s implementation of initial nuclear obligations Implementation Day: Upon IAEA verifications, U.S. and EU sanctions reforms to take effect Important information about the JCPOA sanctions relief Current EU and U.S. sanctions remain intact until they are formally suspended or lifted. Only the regular JCPOA sanction reliefs are extended U.S. and EU non-nuclear related sanctions, such as those for internal repression and human rights abuses, will remain in place U.S. sanctions lift might be less extensive than the EU sanctions lift, so you have to determine which jurisdiction is applicable to you U.S. and EU sanctions can be re-imposed in the event of significant non-performance by Iran of JCPOA commitments
5 Terms of the JCPOA for Iran
6 Iran sanctions lift! What does this mean for your business? Please contact us at: E: T:
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