On Saturday, January 16, 2016, the International Atomic Energy Agency (“IAEA”) certified that Iran had fulfilled its nuclear-related commitments under the Joint Comprehensive Plan of Action (“JCPOA”) in order for the JCPOA’s “Implementation Day” to take effect. Accordingly, EU and US sanctions relief for Iran that was outlined in the JCPOA has simultaneously gone into effect. The US Secretary of State has confirmed the IAEA’s certification and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued the much-anticipated general license authorizing non-US subsidiaries of US companies to engage in certain transactions with Iran or the Government of Iran, along with various guidance documents outlining other OFAC and secondary sanctions relief measures for Iran under the JCPOA. OFAC’s guidance documents are available here. We are reviewing the guidance from OFAC and will post more detailed comments and issue an alert in the coming days.
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