Compliance Initiative

Joint Comprehensive Plan of Action (JCPOA)

The event with the most significant impact and influence of Organisations business with IRAN in managing of compliance programs is the Joint Comprehensive Plan of Action (JCPOA) signed on 14 July 2015, the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom and the United States, with the High Representative of the European Union for Foreign Affairs and Security Policy) and the Islamic Republic of Iran.

The full implementation of this JCPOA will ensure the exclusively peaceful nature of Iran’s nuclear programme.

The JCPOA produced a comprehensive lifting of all UN Security Council sanctions as well as multilateral and national sanctions ( EU and USA mainly) related to Iran’s nuclear programme.

In July 2017 the US has re-certified Iran’s compliance to the JCPOA (the US Administration must certify it every 90 days and notify the Congress, as requested by law).

However, it is worth noting that on August 2nd, 2017 the US President has signed into law n. 155-44 the bill titled “Countering America’s Adversaries Through Sanctions Act”.

The bill, among others, directs the President to impose sanctions against: (i) Iran’s ballistic missile or weapons of mass destruction programs; (ii) the sale or transfer to Iran of military equipment or the provision of related technical or financial assistance; (iii) Iran’s Islamic Revolutionary Guard Corps and affiliated foreign person.

On May 8, 2018, the U.S. President announced his decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA), and to begin re-imposing, following a wind- down period, the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief.

EU, E3 (France, Germany and the United Kingdom) Russia, China, members of the Joint Commission of the JCPOA reiterated their political commitment to the full and continued implementation of the nuclear deal and support to maintain the normalization of trade and economic relations with Iran.

JCPOA Timeline

There are five main events to distinguish in JCPOA process:

  • Finalization Day,
  • Adoption Day,
  • Implementation Day,
  • Transition Day and UN Security Council resolution
  • Termination Day

Therefore during this transition period, all operators must adopt the highest level of compliance to monitor the risk of money laundering and terrorism financing in accordance with the general rules set EU and national level.

What can be done

EU persons and companies can now engage in trade with Iran in the following sectors:

  • financial, banking and insurance sectors
  • oil, gas and petrochemicals sectors
  • shipping, shipbuilding and transport sectors
  • gold and other precious metals
  • other activities that are not specifically prohibited

US  persons and US companies, as a result of November 5th 2018 action all the U.S. nuclear-related sanctions that had been lifted under the JCPOA have been re-imposed and are in full effect including sanctions on associated services related to the activities that were subject to JCPOA.





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