Iran Nuclear Deal P5 + 1 reached a Joint Comprehensive Plan of Sanctions Action

Issuance of Revised Guidance on the Continuation of Certain Temporary Sanctions Relief Implementing the Joint Plan of Action, as Extended

 


On July 14, 2015, the P5 + 1 and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program will be exclusively peaceful.  The JCPOA will provide Iran with phased sanctions relief upon International Atomic Energy Agency (IAEA) verification that Iran has implemented key nuclear commitments. The P5+1 and Iran also decided on July 14, 2015 to further extend the sanctions relief provided for in the Joint Plan of Action (JPOA) of November 24, 2013, as extended. This JPOA sanctions relief is the only Iran-related sanctions relief in effect until further notice. Today, the U.S. government is issuing the following revised Guidance and Frequently Asked Questions relating to the Continuation of Certain Temporary Sanctions Relief Implementing the Joint Plan of Action, as Extended.  The U.S. government is also issuing aThird Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry.
 
 
I. Sanctions Related to Iran’s Export of Petrochemical Products The continued JPOA relief provides for the temporary suspension of U.S. sanctions on “Iran’s petrochemical exports, as well as sanctions on any associated services.” To implement this provision during the JPOA Relief Period, the USG will take the following steps to allow for the export of petrochemical products from Iran, as well as associated services,3 by non-U.S. persons not otherwise subject to section 560.215 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), (hereinafter “non-U.S. persons not otherwise subject to the ITSR”): 1. Correspondent or Payable-Through Account Sanctions: The USG will not impose correspondent or payable-through account sanctions under section 1(a)(iii) of Executive Order (E.O.) 13622 (as amended by section 16(b) of E.O. 13645); section 3(a)(i) of E.O. 13645; and sections 561.204(a) and 561.204(b)(3) of the Iranian Financial Sanctions Regulations, 31 C.F.R. part 561 (IFSR), on foreign financial institutions that conduct or facilitate transactions that are initiated and completed entirely within the JPOA Relief Period by non-U.S. persons not otherwise subject to the ITSR for exports of petrochemical products4 from Iran that are initiated and completed entirely within the JPOA Relief Period, including transactions involving the petrochemical companies listed in the Annex to this guidance, provided that the transactions do not involve persons on the SDN List other than the petrochemical companies listed in the Annex to this guidance or any Iranian depository institutions5 listed solely pursuant to E.O. 13599. 
 
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/guidance_ext_20150807.pdf