Jan. 16 marked Implementation Day, the day the United States announced the lifting of a number of sanctions against Iran under the Joint Comprehensive Plan of Action (JCPOA). This long-awaited action took place in exchange for Iran’s commitment to limit its nuclear program after the International Atomic Energy Agency verified that Iran carried out its nuclear commitments under the JCPOA.
The sanctions relief primarily affects “secondary sanctions” that targeted foreign entities “owned or controlled” by a U.S. person or entity for certain Iran-related activities undertaken outside the United States. It is important to note that prohibitions on U.S. persons with respect to Iran remain in place.
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