The Joint Comprehensive Plan of Action between Iran and six world powers became effective on January 16, 2016 (“Implementation Day”), triggering significant sanctions relief in exchange for Iran curtailing its nuclear program. While the EU has lifted most of its sanctions against Iran and the US has also eased a broad range of sanctions applicable to non-US persons (including non-US subsidiaries of US companies), the US will continue to enforce certain “secondary sanctions” against non-US individuals and entities and maintain the embargo prohibiting most Iran-related activity by US persons. As companies around the world contemplate entering the Iranian market, Steptoe’s advisory provides insight into new areas of opportunity, as well as the complex risks that remain.
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