EU & US introduce measures to prepare for lifting Iran nuclear sanctions

Yesterday, the EU & US took action formally to adopt the JCPOA nuclear deal, on what it terms “Adoption Day”, in accordance with their obligations under the agreement (see also previous blog).  The latest measures make the necessary legal preparations for sanctions to be lifted on “Implementation Day”, when the IAEA confirms that Iran has met its own obligations under the deal.

The EU introduced Council Regulation (EU) 2015/1861, Council Decision (CFSP) 2015/1863, and Council Implementing Regulation (EU) 2015/1862, setting out the changes to its existing anti-proliferation sanctions on Iran that it will be required to make, along with the people and entities who will be de-listed, on Implementation Day.  In the US, President Obama issued a memorandum directing the relevant government agencies to prepare to lift US anti-proliferation sanctions, and the Secretary of State issued contingent waivers of certain statutory sanctions provisions.

In addition, the Joint Commission, a group provided for by the JCPOA to oversee the deal’s implementation, met for the first time today in Vienna. The Commission comprises representatives from the E3/EU+3 states and Iran, and according to Iranian deputy foreign minister Abbas Araqchi, who was in attendance, the first meeting was used to discuss the latest developments relating to the JCPOA, and review what the agreement requires the parties to do between Adoption and Implementation Day.

The US Treasury has published a FAQ on Adoption Day and the action it has taken here, and its press release is here.  A joint statement by EU High Representative Federica Mogherini and Iranian Foreign Minister Javad Zarif is here.

This entry was posted in Iran, Latest EU Measures, USA by Michael O'Kane. Bookmark the permalink.

About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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