On 20 January 2014, as part of the Joint Plan of Action, the U.S. and EU have implemented “limited, targeted, temporary and reversible” relief from certain sanctions measures in return for Iran’s agreement to commence the winding down of certain aspects of its nuclear program. This limited easing is valid for a six-month period only, until 20 July 2014, and if there is no comprehensive agreement with Iran by that time, those EU and U.S. sanctions that have been temporarily suspended will come back into force. We have outlined below key aspects of this development and its impact on U.S. companies (and their non-U.S. subsidiaries) as well as on foreign companies that are not ultimately owned or controlled by U.S. persons/entities.
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