On November 2, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”)announced an expansion of the List of Medical Supplies (“List”) eligible for export or reexport to Iran under the general license at Section 560.530(a)(3) of the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 CFR Part 560. ITSR § 560.530 sets forth a policy of permitting the export and reexport to Iran of certain EAR99 agricultural commodities, medicines and medical devices either by general or specific license. The…
On 18 October 2015 (“Adoption Day”), Iran and the EU/E3+3 (China, France, Germany, the Russian Federation, the United Kingdom, and United States) began preparations to implement their respective commitments under the Joint Comprehensive Plan of Action (“JCPOA”) related to Iran’s nuclear programme. The EU adopted the legislative framework needed to lift its nuclear-related sanctions against Iran, while the U.S. Government issued contingent waivers of certain sanctions. The publication on Adoption Day of measures that would…
On October 18, 2015, President Barack Obama directed US Government agencies to take all appropriate measures to implement US commitments under the Joint Comprehensive Plan of Action (“JCPOA”). This date was “Adoption Day” under the JCPOA, or 90 days after the UN Security Council approved the agreement. We previously summarized the JCPOA in this blog post. This US action is taking place in parallel with similar action by the EU, as summarized in this blog post. In conjunction with…
In accordance with the envisaged timeline, on 18 October 2015 (“Adoption Day”) Iran’s Foreign Minister Mohammad Javad Zarif and the EU Foreign Policy Chief Federica Mogherini issued a joint statement announcing the official adoption of the “Joint Comprehensive Plan of Action” (“JCPOA”) between Iran and the EU/E3+3 (China, the EU, France, Germany, Russia, the UK and the USA). On Adoption Day the JCPOA participants began to make the necessary arrangements for the implementation of their…