On July 14, 2015, Iran and the E3/EU+3 countries1 reached a historic accord called the Joint Comprehensive Plan of Action (JCPOA) that restricts Iran’s nuclear program in return for the easing of nuclear-related sanctions.
Under the deal, the United States promised to terminate all nuclear-related secondary sanctions, those directed at non-U.S. Persons.2 The sanctions relief would focus on (1) financial and banking-related sanctions; (2) sanctions on the provision of underwriting services; (3) insurance or re-insurance in connection with activities that are consistent with the JCPOA; (4) sanctions on Iran’s energy and petrochemical sectors; (5) sanctions on transactions with Iran’s shipping and shipbuilding sectors and port operators; (6) sanctions on Iran’s trade in gold and other precious metals; (7) sanctions on trade with Iran in graphite; raw or semi-finished metals such as aluminum and steel; coal; and software for integrating industrial processes in connection with activities that are consistent with the JCPOA; (8) sanctions on the sale, supply or transfer of goods and services used in connection with Iran’s automotive sector; and (9) sanctions on associated services for each of the above categories.3
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