Iran, 'Implementation Day' and EU guidelines

On 16 January, following confirmation by the International Atomic Energy Agency (IAEA) that Iran had fulfilled its agreed commitments, what is known as “Implementation Day” took place.

From that date, as indicated in our previous communications, the provisions already set out and published in the Official Journal of the European Union—specifically Regulation 2015/1861 and Implementing Regulation 2015/1862—have come into force, taking full effect for the lifting of a large portion of the existing sanctions against the country.

In particular, restrictions have been lifted on the import of “crude oil and petroleum products”, “natural gas and other gaseous hydrocarbons” and “petrochemical products”, as well as those relating to the export to Iran of equipment, materials, software and technology related to “exploration and production of crude oil and natural gas”, “refining of crude oil and liquefaction of natural gas” and the “petrochemical industry”. Restrictions have also lapsed regarding the export to Iran of naval equipment and technology essential for the construction, maintenance or refitting of ships/tankers, the trade in gold, precious metals and diamonds, and transport and logistics services related to goods previously subject to restrictions. Finally, the requirement for financial procedures for transactions with Iran has been removed.

Attached are the texts of the guidelines and “FAQs” made available by the EU External Action Service to assist in understanding the new provisions.