The comprehensive nuclear accord (Joint Comprehensive Plan of Action, or JCPOA), finalized on July 14, 2015, provides Iran broad relief from U.S., U.N., and multilateral sanctions on Iran’s energy, financial, shipping, automotive, and other sectors. Sanctions were suspended or lifted upon the International Atomic Energy Agency (IAEA) certification on January 16, 2016, that Iran had complied with the stipulated nuclear dismantlement commitments under the agreement (“Implementation Day”). On Implementation Day, Administration waivers of relevant sanctions laws took effect and relevant Executive Orders (E.O.s) were revoked by E.O. 13716.
Remaining in place are those secondary sanctions (sanctions on foreign firms) that have been imposed because of Iran’s support for terrorism, its human rights abuses, its interference in specified countries in the region, and its missile and advanced conventional weapons programs. Most sanctions that apply to U.S. companies, including regulations barring transactions between U.S. and Iranian banks, remain in place. Under U.N. Security Council Resolution 2231 (July 2015, most U.N. sanctions terminated as of Implementation Day, but U.N. restrictions on Iran’s development of nuclear-capable ballistic missiles and its importation or exportation of arms remain in place for several years.
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