Iran Sanctions

July 1, 2015

On June 30, 2015, the P5 + 1 (China, France, Germany, Russia, the United Kingdom and the United States, coordinated by the European Union’s High Representative), the European Union and Iran decided by mutual consent to extend the Joint Plan of Action (“JPOA”) for seven days, until July 7, 2015, in order to provide additional time to continue negotiations to reach a final agreement.  The temporary and limited sanctions relief initially provided by the U.S. Government on November 25, 2014 under the JPOA, as implemented through Guidance, Frequently Asked Questions and Statement of Licensing Policy, was also extended through July 7.  All activities conducted in accordance with the sanctions relief must be concluded while the relief remains in effect. 

If an agreement is reached and is transmitted to Congress for review by July 9, Congress will have 30 days to review the agreement under the Iran Nuclear Review Act of 2015, H.R. 1191 (the “Act”).  However, if an agreement is transmitted to Congress between July 10 and September 7, then the review period extends to 60 days, in order to account for the August congressional recess.  During the review period, the President’s ability to relieve sanctions is constrained by the Act.