The Joint Comprehensive Plan of Action (the JCPOA), between the so-called P5+1 countries (United States, United Kingdom, Germany, France, Russia and China) and Iran was formally adopted on Oct. 18, 2015 (Adoption Day) to lift certain sanctions on Iran. Please see our previous blog post for a summary of the JCPOA.

Adoption Day is the initial milestone in implementation of the JCPOA. Accordingly, the President took the first steps to implementation by directing the Secretary of State, the Secretary of the Treasury, the Secretary of Commerce, and the Secretary of Energy to take all appropriate preparatory measures to ensure the prompt and effective implementation of the U.S. commitments under the JCPOA.

While Adoption Day marks an important milestone, the U.S. will not begin to lift sanctions on Iran until “Implementation Day,” which is the date on which the International Atomic Energy Agency confirms that Iran has implemented certain key nuclear-related measures. Implementation Day (and hence the lifting of additional U.S. sanctions) is not expected to occur until spring 2016.

OFAC issued a Frequently Asked Questions Memorandum to answer questions about Adoption Day and what that means for US businesses.

OFAC will provide further guidance on the sanctions measures that will be lifted pursuant to the JCPOA, as well as those measures that will remain in place, prior to Implementation Day. We will continue to keep you informed of any new issued guidance.