Lifting sanctions is so important for Iran’s industries, Iran’s trade will be done easier and transaction costs will be reduced. Sanctions are split into U.S. and Euro ones, which their relief or maintain for specific industries and US or Euro related is defined as bellows.
US Sanctions- Limited Relief | To be lifted on Implementation Day? |
US extra-territorial (or secondary) sanctions that expose non-US persons to US designation risk if they engage in nuclear-related sanctionable activity (as defined under various US Executive Orders associated with Iranian nuclear proliferation) | Yes |
US primary sanctions that prohibit trade and commerce between US persons and Iran as well as trade involving the US financial system or US-origin goods | No, However, OFAC will license certain activities by US persons. These will include aircraft and aircraft parts exports, certain activities of non-US subsidiaries of US companies and US imports of Iranian carpets and foodstuffs. OFAC will also remove from the list of Specially Designated Nationals (SDNs) a number of persons, entities and vessels in order to facilitate their involvement in (a) non-US business of non-US persons and (b) certain OFAC-licensed activities under the sanctions applicable to US person/US financial system dealings. |
EU Sanctions – Sanctions Relief by Sector | To be lifted on Implementation Day? |
Finance, Banking and Insurance
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Yes, Although note that while many banks will be delisted on Implementation Day, some banks will continue to be listed. The prohibition on providing SWIFT services to those banks that will continue to be listed will remain in place until Transition Day. |
Oil, Gas, and Petrochemicals
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Yes, The prohibitions in relation to petrochemical products and transport of Iranian crude oil and on providing insurance / re-insurance related to the import / transport of Iranian crude oil are already suspended until 14 January 2016 under the Joint Plan of Action (entered into on 24 November 2013). |
Shipping, Shipbuilding and Transport
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Yes, Certain measures, including required declarations and prohibitions in relation to prohibited or restricted goods, will remain in force until Transition Day. |
Gold, Precious Metals, Bank Notes and Coinage
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Yes, The prohibitions in relation to gold and precious metals are already suspended until 14 January 2016 under the Joint Plan of Action (entered into on 24 November 2013). |
Other Metals
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Yes, although the scope of the proposed lifting is not clear. These provisions will be amended to allow for ” activities consistent with the JCPOA.” This may mean that exports to the Islamic Revolutionary Guard Corps and related to military use remain in force until Transition Day. |
Software
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Yes, although the scope of the proposed lifting is not clear. These provisions will be amended to allow for ” activities consistent with the JCPOA.” This may mean that exports to the Islamic Revolutionary Guard Corps and related to military use remain in force until Transition Day. |
Arms and Related Materials
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No, restrictions will remain until Transition Day, however authorizations for certain activities will be available. |
Dual Use and other controlled Goods
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Yes, but licenses will still be required for exports and will be refused in certain circumstances. |
Asset Freezes
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Yes, some entities and individuals will be delisted. These include: n certain banks (including the Central Bank of Iran); and n persons, entities and bodies related to the oil, gas and petrochemical sectors or shipping, shipbuilding and transport sectors. Certain other persons will remain listed (and therefore subject to the asset freeze) until Transition Day. |
Collecting by: CLIFFORD CHANCE