Joint Comprehensive Plan of Action (“JCPOA”)


The High Representative of the European Union and the Foreign Ministers of France, Germany and the United Kingdom released a joint statement today (see here for the full statement) following Iran’s announcement yesterday that it would withdraw from certain commitments as agreed as part of the 2015 nuclear agreement (see our post here on this). The statement urged Iran to continue to implement its commitments under the nuclear agreement, stating that Iran’s compliance would be…

President Hassan Rouhani has announced that Iran will withdraw from certain commitments agreed in the 2015 nuclear agreement; this announcement comes a year after the agreement was abandoned by the US, leading to the re-imposition of US sanctions against Iran. In today’s announcement, Hassan Rouhani declared that Iran will stop exporting its surplus enriched uranium. This decision is contrary to the agreement, under which Iran is required to sell its surplus enriched uranium abroad to…

US trade sanctions and export controls targeting Iran have attracted increasing attention from Chinese companies doing business in Iran or with Iran counterparties. This client alert aims to provide a high-level overview on US trade sanctions and export controls targeting Iran, their implications (particularly in terms of their extraterritorial application), and the potential penalties that can be imposed on companies and their executives and employees in the event of violations.

On November 5, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) took several actions to finalize the re-imposition of sanctions against Iran in response to President Trump’s May 8, 2018 decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”). See our previous blog posts here regarding the President’s May 8, 2018 decision to cease the United States’ participation in the JCPOA and here regarding Executive Order (“EO”) 13846, issued on August 6, 2018, which consolidated and reissued several sanctions provisions that had been suspended or revoked while the JCPOA was in effect.