ABA Banking Journal
By Rob Rowe
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on July 14 released a statement on the Joint Comprehensive Plan of Action (JCPOA) regarding Iran’s nuclear program. The deal “will cut off all pathways to a nuclear weapon, cements intrusive inspections that will be at an unprecedented level, and ensures that Iran’s nuclear program will be exclusively peaceful,” said U.S. Treasury Secretary Jacob J. Lew. The P5+1 (China, France, Germany, Russia, the United Kingdom, and the United States) and Iran decided to further extend through Implementation Day the sanctions relief provided for in the Joint Plan of Action (JPOA) of November 24, 2013, as extended. OFAC will issue revised guidance shortly.
The next step in the process will be Congressional ratification of the JCPOA. It is important to recognize that the sanctions that will be lifted are restricted to those that are associated with the Iranian nuclear program and that many other sanctions that restrict transactions involving Iran will continue. Furthermore, the sanctions to be lifted apply to non-U.S. persons or entities and are part of the restrictions put in place to limit interactions with Iran by U.S. trading partners.
Previously, while negotiations were underway and to let the discussions continue, on June 30, the P5+1 extended the JPOA sanctions relief provided on November 25, 2014 for seven days, through July 7, 2015. On July 7, the P5+1 further extended the JPOA for an additional three days, until July 10, 2015. On July 10, the P5 + 1, EU, and Iran decided to further extend the JPOA for an additional three days, until July 13, 2015. OFAC issued guidance on this extension, which replaces the July 7 guidance.
See the Guidance, Frequently Asked Questions, and Statement of Licensing Policy documents of November 25, 2014 for additional details on sanctions relief.
