Reed Smith Client Alerts

Authors: Leigh T. Hansson Michael J. Lowell Siân Fellows

Yesterday, the P5+1 (made up of the United States, Russia, China, the United Kingdom, France and Germany) together with Iran, announced the extension of the Joint Plan of Action (JPOA) Relief Period (JPOA Relief Period) for seven days to continue negotiations of a comprehensive solution.

The suspension and relaxation of sanctions remains in place in identical form. All activities conducted under the JPOA must be concluded by 7 July 2015. No additional sanctions have been suspended.

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has advised that all JPOA sanctions relief detailed in the OFAC Guidance, FAQs, and Statement of Licensing Policy documents of 25 November 2014 are now extended until 7 July 2015. OFAC has also advised that effective 1 July 2015, all specific licenses that were (a) issued pursuant to OFAC’s Second Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry, and (b) have an expiration date of 30 June 2015, are authorised to remain in effect until 7 July 2015.

A brief summary of the JPOA is provided below:

  • On 24 November 2013, the P5+1 and Iran reached agreement on the terms of the JPOA, whereby Iran would comply with restrictions to its nuclear programme in return for limited relief from international trade sanctions. The terms of the JPOA were not immediately implemented; existing sanctions remained in force until the conditions of the agreement were met by the parties. For further detail, refer to our alert of 5 December 2013.
  • On 12 January 2014, both the EU and U.S. temporarily suspended and relaxed (for an initial period of six months) some of the sanctions in place against Iran, called the JPOA Relief Period. Those measures were discussed in our alert of 23 January 2014.
  • At the end of that initial six month period and on 21 July 2014, when no agreement between Iran and the P5+1 could be reached, the JPOA Relief Period was extended for a further six months, to 24 November 2014. For further detail, refer to our alert of 24 July 2014.
  • On 24 November 2014, to allow discussions between Iran and the P5+1 to continue, the JPOA Relief Period was extended to 30 June 2015. The parties noted that the goal was to have the significant points agreed to by March 2015, and the final agreement in place by 30 June 2015. For further detail, refer to our alert of 28 November 2014.

If you have any queries about the contents of this alert, or about sanctions regimes in general, please contact one of the authors of this alert, or your usual contact at Reed Smith.

Client Alert 2015-184