On July 14, 2015, the P5+1, the European Union, and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program will be exclusively peaceful. October 18, 2015 marks “Adoption Day” under the JCPOA – the day on which the JCPOA becomes effective and participants begin to make the necessary preparations for implementation of their JCPOA commitments. In connection with Adoption Day, the President today issued a memorandum directing the Secretary of State, the Secretary of the Treasury, the Secretary of Commerce, and the Secretary of Energy to take all appropriate preparatory measures to ensure the prompt and effective implementation of the U.S. commitments set forth in the JCPOA upon Iran’s fulfillment of the requisite conditions. In particular, the President directed the agencies to take steps to give effect to the U.S. commitments with respect to sanctions described in the JCPOA beginning on Implementation Day, which will occur only once the IAEA verifies that Iran has implemented key nuclear-related measures described in the JCPOA.
In addition, the Secretary of State today issued contingent waivers of certain statutory sanctions provisions. These waivers are not currently in effect and will only take effect on Implementation Day.
Until Implementation Day is reached, the only changes to the Iran-related sanctions are those provided for in the Joint Plan of Action (JPOA) of November 24, 2013, as extended. See the August 7, 2015 revised guidance, Frequently Asked Questions, and the Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry for additional information regarding the sanctions-related commitments under the JPOA. Even after Implementation Day, U.S. persons will continue to be broadly prohibited from engaging in transactions or dealings involving Iran, including the Government of Iran, with the exception of a few specific categories of transactions that OFAC will license pursuant to the JCPOA.
The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Frequently Asked Questions relating to Adoption Day. OFAC will provide further guidance on the sanctions measures that will be lifted pursuant to the JCPOA, as well as those measures that will remain in place, prior to Implementation Day