Implementation Day of the Joint Comprehensive Plan of Action (JCPOA) has been reached

The EU and US have lifted nuclear related sanctions on Iran in accordance with the JCPOA. The new EU measure is here and the US announcement is here. This follows the report from the International Atomic Energy Agency sent earlier today to the UN Security Council verifying that Iran has taken the steps it agreed to take to comply with its side of the JCPOA nuclear deal agreed 6 months ago between the E3/EU+3 and Iran. The IAEA Director General’s statement is here.


This means that the EU has replaced prohibitions on dealing with Iran in dual-use equipment, precious and other listed metals, diamonds, and graphite with a requirement for prior authorisation. Prohibitions on transactions relating to Iranian oil & gas products and related services, provision of engineering and maintenance services to cargo aircraft (not carrying goods on the Common Military List), bunkering and supply services to Iranian vessels, and on certain software have been removed. Several restrictions on financial services have also been removed, including a prohibition on trading in bonds with the government of Iran, a prohibition on providing insurance or re-insurance in Iran or to Iranian persons, and prohibitions on fund transfers to and from Iran.


A large number of people and entities have been de-listed from the EU’s targeted asset freezes on Iran, reducing the number of listed persons from approximately 93 people and 467 entities to 29 and 94 respectively. The JCPOA relates only to the EU’s nuclear-proliferation sanctions on Iran, and so listings under anti-terrorism and human-rights sanctions will remain in force, as well as an arms-embargo.


The US has lifted its nuclear-related “secondary sanctions” on Iran, which are those primarily targeting non US persons conducting business with Iran, including in the oil, banking, and shipping sectors. While the JCPOA carves out some exceptions to the general US trade-embargo on Iran (“primary sanctions”), such as trade in connection with parts for commercial passenger aircraft, the vast majority of it remains in place. As in the case of the EU, US anti-terrorism related sanctions on Iran will remain in force.


The IAEA will now begin verifying and monitoring Iran’s nuclear-related commitments under the agreement. The EU and US reserve the right to “snap back” sanctions on Iran, if Iran is found to have violated its obligations. Following Implementation Day, the JCPOA provides for Transition Day, 8 years from July 2015 or when the IAEA director-general concludes that all nuclear material in Iran remains for peaceful activities, the EU will terminate any remaining nuclear-related sanctions on Iran, and the US will do the same or modify its remaining sanctions. In return, Iran will ratify an Additional Protocol on enhanced inspections. 10 years from July 2015, provided no UN sanctions have been reinstated the UN will pass a resolution terminating the JCPOA and will no longer be seized of the Iran nuclear issue.


UPDATE: Joint Statement P5+1: Joint Comprehensive Plan of Action (JCPOA) agreed Parameters: a solution to Nuclear/Embargo issue. 

The 5 permanent members of the UN Security Council, plus Germany (the P5+1) have announced they have agreed the "key parameters" of an agreement with Iran on nuclear weapons and sanctions, to be drafted by the end of June. The parameters, so far as sanctions are concerned, are: JCPOA_parameters_IRAN_EU_USA.pdf

1) US and EU nuclear-related sanctions will be suspended after the International Atomic Energy Agency has verified that Iran has taken "all of its key nuclear-related steps". If at any time Iran fails to fulfill its commitments, these sanctions will "snap back into place".

2) All past UN Security Council resolutions on Iranian proliferation will be lifted with the completion by Iran of "nuclear-related actions addressing all key concerns". Core provisions in the UN Security Council resolutions – those that deal with transfers of sensitive technologies and activities – will be re-established by a new UN Security Council. Restrictions on arms and ballistic missiles, and provisions that allow for related cargo inspections and asset freezes, will also be incorporated by this new resolution.

3) US sanctions on Iran for terrorism, human rights abuses, and ballistic missiles will remain in place.

UPDATE: Extended the JPOA till 30/06/2015. Play by the Rules Initiative: Iran. EU, USA and Iran extend the Action Plan:  a solution to Nuclear/Embargo issue. 

Following up the Action Plan signed in Geneva on 24/11/2013, EU and USA have decided to begin the implementation of a six-month phase of initial confidence-building measures aimed at addressing international concerns about Iran's nuclear activities.

Given the technical complexity of the agreement to be reached, the Foreign Ministers of the E3+3, have therefore agreed on 24/11/2014 to continue their diplomatic efforts. It has have decided to extend the measures of the Joint Plan of Action to allow for further negotiations until June 30th.

All the parties intend to build on the current momentum in order to complete these negotiations within the shortest possible time, up to four months, and if necessary to use the remaining time until the end of June to finalize any possible remaining technical and drafting work.

Iran and the E3/EU+3 have reaffirmed that they will continue to implement all their commitments described in the Joint Plan of Action in an efficient and timely manner.

The IAEA will be asked to continue monitoring the voluntary measures under the Joint Plan of Action.


eu EU COUNCIL REGULATION of 20 January 2014 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran (2014/42/EU)

us Second amended statement of licensing policy on activities related to the safety of Iran’s civil aviation industry

us Guidance relating to the provision of certain temporary sanctions relief in order to implement the joint plan of action reached on 24 November 2013, between the p5+1 and the Islamic Republic of Iran

us Frequently Asked Questions Relating to the Temporary Sanctions Relief to Implement the Joint Plan of Action between the P5 + 1 and the Islamic Republic of Iran



Play by the Rules Initiative: Iran. EU, USA and Iran sign an Action Plan:  a solution to Nuclear/Embargo issue. 

EIFEC is pleased to record that a Joint Plan of Action between EU, USA, Russia, China, Germany has been signed in Geneva on 24th November 2013.

In this JPA has been included (pag.3) the principle to establish a financial channel to facilitate humanitarian trade. It was the goal of the Play by Rules Initiative of EIFEC.

EIFEC has been promoting a justice principle – inter alia – incorporated in a global multi stakeholders action plan which took the name: Play by the Rules Initiative.

In a globally integrated world, efficient Export Compliance and Control with laws is only possible with co-operation at an European and international level. All the parties involved expect this process to be transparent and to take place in compliance with the law, regulations as well as in due respect of ethical principles.

The key justice principle promoted is: Parties believe that whoever acts accordingly and in full compliance to rules, laws, legislations, regulations, authorizations, should be not discriminated or disadvantaged / disparage with others, to achieve their legal, compliant and legitimate pursue of business activity.

In short, whoever give rules to be follow must assure that recipients, not only must but, can play by the rules they have given. A valid principle applicable from children playground up to State Regulator activity.

The case of IRAN

Many instances has been raised and put to our attention that a necessity of clarification upon agreed procedure, practices and understanding was needed in the spirit of full cooperation between allied countries as strategic response to threat of non compliance with existing complex layers of regulations.

EU entities wish to maintain maximum legal and ethical certainty within the EU and USA concerning the application and implementation of Sanction on IRAN, thus promoting a full international compliance culture.

Mid of 2012 EIFEC has issued a Road Map with a proposal for implementing Play by the rules initiative for IRAN.

A comprehensive Request for Clarification and Opinion document (RFCO) has been presented to US Government ( OFAC and BIS), to European Commission and to the EU Member state Ministry of Finance chosen as Pilot Project Country.

The RFCO has been progressively adapted in accordance with new regulations and discussions held with relevant authorities and stakeholders.

The problem to address:

The Sanctions are de facto affecting not only sanctioned goods or persons and organization but all iranian people and even items which are essential to the livelihood as medicines, food, agricultural products and legitimate or authorized commercial trade, are very difficult to deliver as the payments processes are almost blocked.

Who is compliant with the regulations and accepts to “play by rules” that EU and USA have laid down should not be de facto discriminated or discouraged but treated with equality to any other rights holders in our countries.

Therefore in order to allow people and organizations that are in accordance and compliance to EU/USA Regulations to transact in verifiably and orderly way the initiative “play by the rules” will readdress the non compliant situation de facto created by misunderstanding between the actors where who wish to play by the rules cant play as almost no one wants to play. the recognition and promotion of the good of each individual is a specific duty for every person. The order of justice is not static but dynamic, because the very life of individuals and communities is in itself dynamic.

The Proposed action in short:

(i) Five (5) EU banks will have the possibility to maintain or open a corresponding bank account to a maximum number of 5 NON EU LISTED /NON US SDN private reputable iranian banks (hereinafter “IRANBANKS”) (ii) EUBANKS may receive on these accounts funds and any other permitted financial instrument to be used only for the payment of: a. Foodstuff b. healthcare, c. medical equipment d. humanitarian purposes e. Goods with authorization (the EU Member State Ministry of Economy and Finance (iii) The EU authorities will facilitate these financial channel for humanitarian trade. (iv) Specific schemes for maintaining the highest transparency and compliance have been outlined. The benefits. (i) The major benefit is the maintenance of maximum legal and ethical certainty for organizations in EU that will act accordingly to this initiative. (ii) Encouraging people and organization to comply laws easing the way to do it is an act of justice. (iii) No cost are involved will derive from this initiative (iv) Will allow the people of Iran to access again the food and agricultural products, medicine, medical devices, and medical expenses, without the burden of black market.

This Initiative has been object of several agreements. In Iran several EU Export Compliance Agreements (EU-ECA) have been inked with the Red Crescent Society of Iran and The Central Bank of Iran ( Bank Markazi).

EU USA IRAN Plan of Action  24/11/2013

EU RFCO - Play by the Rules Initiative Document 

USA RFCO Play by the Rules Initiative Document 

EU Road Map - Play by the Rules Initiative: Iran