On July 14, 2015, the U.S. government announced that together with China, France, Germany, Russia, the EU and the U.K., it had reached an agreement with Iran to roll back Iran’s nuclear program in exchange for sanctions relief.  The Joint Comprehensive Plan of Action (JCPOA) which outlines the deal discusses the phased sanctions relief which would occur upon verification that Iran has met its nuclear commitments.  The relief will involve suspension and eventual termination of nuclear-related sanctions.  The International Atomic Energy Agency will be responsible for the verification.            

        Also on July 14, the Department of the Treasury, Office of Foreign Assets Control (OFAC) announced that it will provide detailed guidance prior to implementation of the JCPOA, and further noted that the sanctions relief provided in the 2013 Joint Plan of Action will stay in place until the new agreement is implemented.  For the moment, current restrictions remain in force.  While we can expect the sanctions relief to be set out in detailed OFAC regulations, if Iran were to breach the agreement, they could be reinstated, upon certain procedures being followed.
        There have been vocal objections to the deal by some members of Congress.  However, it is unlikely that Congress will scuttle the deal, as by previous agreement, the deal is subject to a special 60 day legislative review, giving President Obama the authority to veto any Congressional attempts to block the deal.  On July 15, the President warned that he would use this veto if necessary.  Thus, it is likely that the deal will stand, and that significant changes to the Iran sanctions are on the way.    
 

Please contact a Barnes/Richardson attorney if you have further questions.