US Lifts Nuclear-Related Sanctions on Iran
- Schulz Trade Law
- Nov 29, 2016
- 2 min read
Updated: Jun 4
US Lifts Nuclear-Related Sanctions on Iran
What It Means for International Trade Compliance
On January 16, 2016—known as “Implementation Day”—the United States officially lifted certain nuclear-related sanctions on Iran under the Joint Comprehensive Plan of Action (JCPOA). Following verification by the International Atomic Energy Agency (IAEA) that Iran had met its nuclear commitments, the U.S. removed select secondary sanctions, creating new opportunities for non-U.S. companies to engage in trade with Iran.
Limited Relief for U.S. Companies
Despite the significant move, the primary U.S. trade embargo on Iran remains in effect. For most U.S. businesses, transactions involving Iran are still broadly prohibited under existing sanctions law. However, three key areas of limited relief are now authorized:
Export of Commercial Aircraft and PartsU.S. and foreign companies may apply for a license to export or lease aircraft and related services for civil aviation use only.
Import of Foodstuffs and CarpetsA general license now permits U.S. imports of Iranian-origin carpets and foodstuffs (e.g., pistachios and caviar).
Foreign Subsidiaries of U.S. Companies (General License H)Non-U.S. entities owned or controlled by U.S. persons may conduct business with Iran—but with strict limitations and compliance requirements.
Sanctions Relief for Non-U.S. Persons
The U.S. lifted certain secondary sanctions affecting non-U.S. persons engaged in trade with Iran in sectors like:
Energy, shipping, and shipbuilding
Trade in metals, gold, and software
Automotive and civil aviation sectors
Financial and insurance services
However, U.S. persons may not participate in these transactions, and such transactions must not involve the U.S. financial system.
Compliance Still Essential
Even with this sanctions relief, businesses must navigate a complex legal environment governed by the Office of Foreign Assets Control (OFAC). Specific and general licenses are still required, and any transaction with Iran demands careful due diligence and legal oversight.
Considering business with Iran under JCPOA-related relief?Schulz Trade Law can help you evaluate risk, apply for OFAC licenses, and ensure full compliance with U.S. sanctions regulations. Contact Michelle Schulz or Elsa Manzanares for tailored legal guidance in international trade law.
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