The EU has privately warned Iran that it will be forced to begin the process of withdrawing from the JCPOA in November if Iran goes ahead with its threat to take new steps away from the deal. If it does then the EU has stated its next step would be to commence the JCPOA’s dispute resolution mechanism, which can be instigated if a JCPOA participant believes that another participant is not meeting its agreed commitments. The mechanism provides an opportunity for the issue to be resolved. If it is not and the issue is deemed to constitute “significant non-performance”, then the UN Security Council will be asked to vote on whether sanctions relief should continue under the JCPOA. A UN Security Council resolution is adopted if: (i) 9 of the 15 Security Council members vote for the resolution; and (ii) no veto is received from any of the five permanent members (United States, United Kingdom, France, Russia, and China). Businesses will be observing developments closely as it could result in the reintroduction of tighter sanctions against Iran by the UN, the EU and other countries.
About Sunny Mann
Sunny Mann is a Partner in the Compliance & Investigations Group of Baker & McKenzie’s London office. He has also worked in our Firm’s Washington DC,New York and Sydney offices. He advises clients on compliance with respect to international trade and anti-bribery rules. He has advised numerous FTSE 100 and Fortune 100 clients on general compliance, risk assessments, systems and controls, training, audits, as well as government investigations and disclosures. He also spent 9 months working on secondment with a major UK mobile network operator and a further 3 months on secondment with a major manufacturer of high-tech consumer goods. The Legal 500 described Sunny as “highly rated” and “‘excellent’, with a ‘calm’ and ‘very practical’ approach”. He is a Visiting Professor at the College of Europe (Bruges), the leading institute for post-graduate European studies, where he teaches a Masters course on corporate compliance.