JCPOA will be formally adopted on 18 October
An agreement has been reached between US, UK, Germany, France Russia, China, EU, and Iran called the Joint Comprehensive Plan of Action (JCPOA) to pave the path towards easing of Iran sanctions.
The JCPOA will be formally adopted on 18 October. At that point, a ten year time line on which the plan is structured will begin. Sanctions relief will then be phased in as Iran takes verifiable steps to fulfill its commitments with respect to its nuclear program.
No sanctions will however be lifted until the so called Implementation Day, which is the date when the IAEA has verified that Iran has implemented certain key measures including disposal of 98 of its enriched uranium and two thirds of its centrifuges used for enrichment. Implementation Day is expected to occur sometime in the spring of 2016.
However, it is clear already today that certain sanctions will remain in place after Implementation Day, such as the following:
- Transactions with entities and individuals that have contributed towards nuclear proliferation activities or on the SDN list
- Transactions (including shipping of) equipment and technology pertaining to missiles, chemical weapons, nuclear, production and transportation of uranium and mining activities
- Transactions in support of IRGC
- Shipping of material and technical support to Irans military, internal terrorism or human rights abuse
As a result, operators who are involved in shipping cargo to and from Iran are advised that extensive due diligence processes, including knowledge of the end use of the cargo, will be required also after Implementation Day in order not to fall foul of US or EU sanctions legislation. Operators are also advised that sanctions can be reinstated after Implementation Day on a short notice. Breach of sanctions legislation will, among other things, trigger various sanction exclusions in the insurance policies.
For more detailed information about the future of Iran sanctions please see Advisory note provided by US lawfirm Arnold & Porter LLP
Source: The Swedish P&I Club