Recent lifting of the EU nuclear-related sanctions against Iran: some business restrictions still apply!

​This newsflash is intended to provide you with general practical information concerning the lifting of EU sanctions, the scope and limits of this measure and also to remind you of Iran’s status with respect to the international AML/CFT framework.

10/02/2016

​Further to the verification by the International Atomic Energy Agency (IAEA) that Iran has implemented the agreed nuclear-related measures as set out in the Joint Comprehensive Plan of Action (JCPOA), the Council of the European Union terminated all EU nuclear-related economic and financial sanctions on 16 January 2016 (I).

This statement does not however mean that all business restrictions sanctions have ceased to apply to Iran. Some proliferation-related sanctions and restrictions against Iran will indeed still be applicable while the sanctions imposed by the EU in view of the human rights situation in Iran, support for terrorism and other grounds also remain in place (II).

Finally, enhanced due diligence is required for any operation with Iran whose anti-money laundering and combating the financing of terrorism (“AML/CFT”) regime is still considered to have substantial and strategic deficiencies (III).

This newsflash is intended therefore to provide you with general practical information concerning the lifting of EU sanctions, the scope and limits of this measure and also to remind you of Iran’s status with respect to the international AML/CFT framework.

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Philippe-Emmanuel Partsch

Philippe-Emmanuel Partsch is the partner in charge of the EU Financial & Competition Law practice of Arendt & Medernach. He specialises in EU and Luxembourg competition law, regulatory aspects of mergers and acquisitions, State aid rules, EU banking and financial law, tax law, telecommunications, public procurement and environmental law. Philippe-Emmanuel advises a wide range of public and private clients, both nationally and internationally, on EU and competition law and sectoral regulation. He represents them before regulatory authorities and the EU and national courts. In addition, he is a member of several high-level Committees within the Luxembourg financial sector and of the Comité Fra...

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