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'Implementation Day' Marks Rollback of Significant Nuclear-Related Sanctions on Iran

By Lisa A. Prager, Betty Santangelo, Gary Stein, Peter H. White, Lara Covington, Seetha Ramachandran, Michael P. Court and Matthew J. Moses
June 01, 2016

On Jan. 16, 2016, Secretary of State John Kerry confirmed the International Atomic Energy Agency's (IAEA) determination that Iran implemented its key nuclear-related measures as described in the Joint Comprehensive Plan of Action (JCPOA). Thus, Jan. 16, 2016 was “Implementation Day” under the JCPOA. As a result of Iran verifiably meeting its nuclear commitments, the United States lifted certain sanctions primarily applicable to non-U.S. persons, including foreign entities owned or controlled by U.S. persons, as discussed below. In addition, the United States removed over 400 individuals and entities from the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List), the Foreign Sanctions Evaders List (FSE List) and/or the Non-SDN Iran Sanctions Act List (NS-ISA List).

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