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

  • Prohibition on transfers of funds to/from Iranian banks (and the requirement to obtain authorizations and make notifications for such transfers and other transfers to Iran)
  • Restriction on EU banks opening new accounts, offices or establishing certain business relationships with Iranian banks (and vice-versa)
  • Prohibition on specialized financial messaging services (including SWIFT) to listed banks and other listed persons
  • Prohibition on the provision of insurance and reinsurance
  • Restrictions in relation to Iranian government bonds
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

  • Prohibitions relating to the import/transport, purchases of Iranian crude oil or petroleum products, Iranian natural gas, Iranian petrochemical products
  • Prohibitions against sales, supplies, exports of equipment and technology associated with those industries
  • Prohibitions against provision of certain financial services relating to those industries, including loans, loans/credits to, or new/ extended participation in / JVs with, Iranian persons engaged in those industries
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

  • Prohibitions against export of certain naval equipment and technology and services in respect of Iranian oil tankers and cargo vessels
  • Supplying vessels designed for transporting or storing oil / petrochemical products to Iranian persons – suspended
    until 14 January 2016 under the Joint Plan of Action
    (entered into on 24 November 2013)
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

  • Prohibition against sales, supplies, exports or transport of gold / precious metals / diamonds (and related services)
  • Restrictions relating to new currency deliveries
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

  • Prohibition against sales, supplies, exports or transport of specified graphite and raw and semi-finished metals to Iranian persons or for use in Iran (and related services)
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

  • Prohibition against the sale of certain software for integrating industrial processes to Iranian persons or for use in Iran
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

  • Export to Iranian persons or for use in Iran of goods and technology on the EU Common Military List (and related services) n Import from Iran of goods and technology on the EU Common Military List
No, restrictions will remain until Transition Day, however authorizations for certain activities will be available.
Dual Use and other controlled Goods

  • Import/export of dual use items and other listed nuclear-related items to Iranian persons or for use in Iran
Yes, but licenses will still be required for exports and will be refused in certain circumstances.
Asset Freezes

  • Requirement to freeze funds of listed persons and prohibition against making funds available to them
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