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Overview
On January 16, 2016, “Implementation Day” arrived under the Joint Comprehensive Plan of Action (JCPOA), bringing into effect the commitments of the United States (U.S.) and European Union (EU) to lift certain sanctions in response to verification that Iran had met commitments to limit its nuclear program. For the U.S., this includes delisting of hundreds of Iranian and Iran-related Specially Designated Nationals (SDNs); issuance of general licenses for non-U.S. entities owned or controlled by U.S. persons to engage in certain activities in Iran and authorizing certain imports into the United States; and adjustment of licensing policy to allow authorization of certain exports in the civil aviation area.
Some of the changes to Iran sanctions are complex and nuanced. For companies considering doing business with Iran, it is important that these differences be understood and carefully navigated.
Sanjay Jose Mullick of Pillsbury Winthrop Shaw Pittman LLP and Kim Strosnider of Covington & Burling LLP will discuss:
• The basic background of the JCPOA leading up to Implementation Day
• Which sanctions have been lifted and which remain in place
• Impact on various industry sectors such as aviation, energy, and financial institutions
• The different effects of the easing on U.S. companies and their foreign subsidiaries