On 24 November 2013, the E3/EU+3 (or the P5+1, comprising the United States, Russia, China, the United Kingdom, France and Germany), together with Iran, agreed the Joint Plan of Action (“JPOA”), which relaxed some of the sanctions imposed against Iran by the EU and the United States.

The JPOA was intended to provide interim sanctions relief, which would take effect while the parties worked towards a more comprehensive and long-term resolution.

The focus of the JCPOA is to ensure that Iran’s nuclear programme is “exclusively peaceful”. The preface to the main JCPOA document states that it will “produce the comprehensive lifting of all UN Security Council sanctions as well as multilateral and national sanctions related to Iran’s nuclear programme, including steps on access in areas of trade, technology, finance and energy”.

In support of these aims, the JCPOA provides for specified voluntary steps to be taken by Iran and the E3/EU+3. It contemplates a staged, measured and long process.


  • The EU and the United States have agreed to lift the majority of nuclear-related sanctions against Iran, provided Iran first implements certain agreed measures for its nuclear programme. If certain goals are reached, the UN arms embargo could be removed in five years, and the restrictions on ballistic missile technology could be lifted in eight years. The implementation of such measures must be verified by the International Atomic Energy Agency (IAEA).
  • There is no immediate change to the sanctions position. All sanctions as relaxed by the JPOA on 20 January 2014 remain in place for the time being. A plan has been agreed, however, which may lead to an eventual lifting of certain sanctions. It is not possible at this stage to put a precise date on when any such lifting of sanctions will occur.
  • The EU has adopted Decision (CFSP) 2015/1148, which extends the JPOA moratorium to 14 January 2016, to allow time for the necessary arrangements and preparations for implementing the JCPOA.
  • Any lifting of sanctions will not be wholesale; rather, it will be a staged process. It should not be assumed that all business with Iran will be permitted once the JCPOA is implemented.
  • If Iran does not comply with its obligations under the JCPOA, provision is made for sanctions to be re-imposed.

For further details, please see the recent Reed Smith Client Alert by Sian Fellows, Leigh Hansson, Michael Lowell, David Myers, Hena Schommer, Alexandra Allan and Alexandra Gordon.