Worldwide: 14 July 2015: Iran, Sanctions And Joint Comprehensive Plan Of Action ("JCPOA")

Last Updated: 14 July 2015
Article by Nigel Kushner

Iran Sanctions Relief

The Islamic Republic of Iran and the G5+1 group of countries - the United States, Britain, France, Russia and China plus Germany - together with the EU foreign policy chief finally reached an agreement to end sanctions against Iran on Tuesday July 14, 2015 after 22 months of intensive talks.

When will Sanctions Relief happen?

Before the US and EU implement meaningful economic and sectoral sanctions relief (together with removing the asset freeze) which will have the effect of significantly opening the Iranian market, the IAEA will have to confirm that Iran has fulfilled certain technical steps and reported them to the UN Security Council.

The 3 step procedure is as follows:

Step 1

Finalisation Day

Promptly after the conclusion of the negotiations of the JCPOA, a proposed UN Security Council Resolution will be submitted to the UN Security Council for adoption without delay. The EU will promptly endorse the UN Security Council resolution through Council Conclusions. This resolution will terminate the main UN Security Council resolutions in place concerning Iran. This should happen in the coming days or weeks.

Step 2

Adoption Day

Adoption Day will occur 90 days after the UN Security Council Resolution implemented at Step 1 above "or at an earlier date by mutual consent". On Adoption Day the EU and U.S. will adopt appropriate measures terminating (or waiving) almost all of the Iranian related sanctions but these will only come into effect upon the Implementation Day at Step 3. Adoption Day will likely occur within the next 2 -3 months.

Step 3

Implementation Day

This will occur upon the IAEA-verified implementation by Iran of at least 11 of the nuclear-related measures set out in the JCPOA and, simultaneously, the EU and U.S. implementing the appropriate measures terminating (or waiving) almost all of the Iranian related sanctions.

We consider that Implementation Day will not occur for many months at the earliest and may take much longer.

What does it mean for business?

We have already seen clients ramp up their marketing efforts in Iran over the last 12 months. However, legitimate business continues to remain challenging and complex. On the one hand, there will be a wholesale easing of US and EU sanctions on Implementation Day - which may still be some way off and depends on successful implementation by Iran of its commitments.

The banking sanctions and prohibitions on the oil & gas and petrochemical and steel sectors may well be removed although this may be some months away at the very best of estimates.

However, the big question is whether the Western banking system will now allow its customers to have dealings with Iran. If they do not, then international business will be able to legitimately conduct trade but will have its hands tied behind its backs in the sense their banks will refuse to allow them to receive payment – even though it is legitimate to do so. We expect customers to be lobbying their banks over the coming weeks and months.

Further, we anticipate that the billions of dollars of previously blocked funds which will now be released may in part be earmarked to pay listed Western suppliers. This will provide the West transparency over the use of unblocked funds. Therefore, expect international business to jockey for pole position in an effort to become an exclusive supplier.

A "sanctions snap-back" forms part of the deal. If the West feels Iran has not lived up to its side of the bargain then sanctions may snap back within 65 days. Some international businesses continue to tread carefully and are reticent to rush back into the Iranian market, fearful that sanctions may snap back, preventing performance of contracts agreed but not yet fulfilled.


Some reports have suggested Iran's annual economic growth could increase by three per cent in the year following a nuclear deal, with estimates pegging it at seven or eight per cent at 18 months post-deal — the same rate of growth as some of Asia's "tiger economies."

Little thought has been given as to how sanctions relief will impact Iran politically and internally. For example, how will Iran and its economy cope with a sudden deluge of unblocked funds and opportunities?

How will the powerful middlemen who made fortunes brokering black market deals during the sanctions regime react to their loss of power and fortunes?

What does the JCPOA actually say?

The JCPOA runs to some 159 pages. In summary:

  • Iran's nuclear program that was introduced as a threat to global security will now be recognized as a field for international cooperation with other countries.
  • Iran will be recognized by the UN as a country with nuclear technology and be entitled to rights of peaceful nuclear program including enrichment and full fuel cycle.
  • All UN economic and financial sanctions against Iran will be removed through a new Security Council resolution.
  • All nuclear facilities in Iran will retain their activities. Contrary to the initial demands of the other side, none of the nuclear sites will be shut down -Iran will continue nuclear enrichment.
  • Iran's nuclear infrastructure will be preserved. No centrifuge will be destroyed and research and development on all advanced centrifuges including IR-4, IR-5, IR-6 and IR-8 will continue.
  • Arak heavy water reactor will remain. Any demands to return the facility to a light water reactor have been dismissed. The facility will be modernized and enjoy new additions through cooperating with owners of most advanced and secure world technologies.
  • Iran will enter global markets as a producer of nuclear products especially in the case of 'enriched uranium' and 'heavy water'. All sanctions and limitations against imports and exports of nuclear material will be annulled.
  • All economic and financial sanctions in the fields of banking, oil, gas, petrochemicals, insurance, and transportation as imposed by the EU and the US under the pretext of Iran's nuclear program will be immediately lifted upon the implementation of the agreement.
  • Ban on Iran's missile activities including ballistic missiles will be limited to missiles designed for nuclear weapons.
  • Iran's arms embargo will be lifted, replaced with some restrictions to be removed in 5 years.
  • Ban on purchasing sensitive dual-use items will be lifted and Iran's needs will be met more easily through Iran and 5+1 joint commission.
  • Ban on Iranian students studying in the fields related to nuclear energy will be fully lifted.
  • For the very first time, the ban on the purchase of passenger aircrafts will be lifted and Iran will be provided with the opportunity to reconstruct the country's air fleet and improve its flight security.
  • Billions of Iran's blocked revenues in foreign banks will be unfrozen.
  • A total of 800 individuals and legal entities, including the Central Bank of Iran (CBI), the Islamic Republic of Iran Shipping Lines and the National Iranian Oil Company (NIOC), will be released from any sanctions.
  • Iran's access to trade, technology, financial and energy will be facilitated.
  • Ban or limitations on Iran's economic cooperation in all fields including investment in oil, gas and petrochemical industries will be removed.
  • Iran will be offered international cooperation for building nuclear power plants and research reactors.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.