The landscape vis-à-vis Iranian sanctions is changing, creating potential new compliance challenges for U.S. companies with international operations, as well as for non-U.S. companies with a significant U.S. presence. On July 14, 2015, Iran reached an agreement with the United States, Russia, China, the European Union, the United Kingdom, France and Germany to ease economic sanctions provided that Iran winds down aspects of its nuclear program. The date that sanctions will be lifted under the agreement, which is called the Joint Comprehensive Plan of Action (JCPOA), is estimated to occur sometime in the first or second quarter of 2016.
Assuming that Iran satisfies its commitments, the EU will lift nearly all of its economic and financial sanctions, but the United States will only suspend or terminate some sanctions, and leave its broad embargo in place. As such, there will be very limited opportunities in Iran for U.S. companies. In contrast, there will be significant opportunities in Iran for EU companies, many of which are reportedly considering re-entering the Iranian market.
