US-Iran Trade Possibilities Continue to Move Forward

On July 14, 2015, the United States, the European Union, and other negotiators concluded a deal with Iran called the “Joint Comprehensive Plan of Action” (JCPOA).  The purpose of this deal was to ensure that Iran’s nuclear program will be exclusively peaceful, and to open up trade with Iran.

Yesterday, Sunday October 18, 2015 was the “Adoption Day” under the JCPOA.  This is the day on which the JCPOA becomes effective.  Starting today, US government officials are acting to make the necessary preparations for implementation of their JCPOA commitments.

In connection with Adoption Day, yesterday, the President issued a memorandum directing the Secretary of State, the Secretary of the Treasury, the Secretary of Commerce, and the Secretary of Energy to take all appropriate preparatory measures to ensure the prompt and effective implementation of the U.S. commitments set forth in the JCPOA upon Iran’s fulfillment of the requisite conditions.  In particular, the President directed the agencies to take steps to give effect to the U.S. commitments with respect to sanctions described in the JCPOA beginning on Implementation Day, which will occur only once the IAEA verifies that Iran has implemented key nuclear-related measures described in the JCPOA.

In addition, on October 18, 2015, the Secretary of State issued contingent waivers of certain sanctions provisions.  These waivers are not currently in effect and will only take effect on Implementation Day.

Until Implementation Day is reached, it is still possible to use Treasury Department licenses to ship aircraft parts to Iran.