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ARTICLE · 21 JANUARY 2016

Implementation Day Triggers Significant Changes To International Sanctions Against Iran

Jones Day
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This Commentary provides a brief overview of the sanctions lifted on January 16 and the resulting regulatory changes for U.S., EU, and international companies.

GlobalInternational Law
Jones Day
Jones Day
Laura Fraedrich
Laura Fraedrich
Michael Gurdak
Michael Gurdak
Chad Dorr
Chad Dorr
Fahad Habib
Fahad Habib
Chase Kaniecki
Chase Kaniecki
Henry Klehm III
Henry Klehm III
Robert Mayo
Robert Mayo
Paul Hines
Paul Hines
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International sanctions on Iran changed drastically on Saturday, January 16, 2016. After months of anticipation and speculation, the International Atomic Energy Agency ("IAEA") announced that it has verified that Iran has fulfilled its commitments under the Joint Comprehensive Plan of Action ("JCPOA"). This triggered Implementation Day, the latest and perhaps most significant milestone contemplated by the agreement reached on July 14, 2015, and the day on which the international sanctions relief contemplated by the JCPOA comes into effect. Although Implementation Day has undoubtedly been reached far earlier than originally predicted, United Nations, United States, and European Union authorities have promptly lifted certain international sanctions, as required by the JCPOA, and provided extensive guidance regarding the scope of the newly enacted sanctions relief. This lifting of sanctions significantly widens the scope of activities in which many international companies

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