A summary of sanctions to be lifted in the Implementation Day:
- US secondary sanctions exposing non-citizen persons in case of any engagement in nuclear-related activities exposed to the United States sanctions.
- EU sanctions addressing financial sectors including fund transfer to/from Iranian banks, cooperation between Iranian and European banks, specialized financial messaging services (such as SWIFT), insurance and reinsurance, and Iranian government bonds. However, some entities will continue to be listed, not able to get SWIFT services until the Transition Day.
- EU sanctions against oil, gas and petrochemical sectors, including purchases of Iranian petro products, prohibitions against technology and equipment associated with the industry, and sanctions against providers of financial services to the oil and gas industry.
- EU sanctions against Transportation and shipping sectors are mostly supposed to be lifted, although certain measures of restriction for prohibited goods stay effective until the Transition Day.
- EU restrictions against sales, supplies, transport and export of precious and base metals including gold and coinage, raw and semi-finished products, banknotes and currency deliveries, as well as software for integrating industrial processes. It should be noted that few entities continue to be listed until the Transition Day.
- Import/export and sales of dual use and controlled goods are possible only by obtaining required licenses which may be refused in certain circumstances.
- In case of asset freezes, some entities and persons will be delisted including some commercial banks, the central bank, and those related to oil, gas, petrochemical, shipping, shipbuilding and transport sectors. Some entities and persons will continue to be listed until the Transition Day.
A summary of sanctions which are not supposed to be lifted on the Implementation Day:
- US primary sanctions against American citizens, prohibiting commercial and financial interactions with Iranian entities, including goods with US origins.
However, OFAC will provide convenient licenses for certain activities by US entities and persons including export of aircraft and aircraft parts and import of some Iranian products such as carpets.
Some people and entities are agreed to be removed from the SDN lists in order to assist them managing their investments and non-US operations exposed to sanctions.
- Prohibitions against import and export of arms and military materials continue to be effective until the Transition Day, although some related activities may be possible by obtaining corresponding permissions.
It can be concluded that although the provisions for lifting nuclear-related sanctions don’t cover all sanctions, most economically important restrictions are supposed to be removed by the Implementation Day, insisting the potential for international investors.
The snap-back mechanism may be worrying, but the underlying reality suggests that all parties become committed to the deal since any dissatisfaction may jeopardize the whole agreement, something that no party wants. Moreover, as explicitly stated in the JCPOA, even if the snap-back process comes into effect and sanctions return to practice, those entities and persons involved in deals made before the snap-back time would not be exposed to returned sanctions.