In the Joint Comprehensive Plan of Action (JCPOA), Iran and the E3+3 states have agreed among other things on a roadmap for the gradual reduction of Iran sanctions. With the adoption of Regulation (EU) No 1861/2015, the European Union (EU) now fulfilled one of its essential obligations under the JCPOA. This Regulation removes substantial EU sanctions against Iran and largely replaces them with a licensing requirement.
Repeal of Iran sanctions is not yet applicable
It should be noted, however, that the repeal is in force, but still not applicable. According to the JCPOA, the Director General of the International Atomic Energy Agency (IAEA) must first submit a report to the IAEA Board of Governors and the UN Security Council confirming that Iran has fulfilled its obligations under the JCPOA. The applicability of the repeal will be published in the Official Journal of the EU. Until then, the sanctions shall continue to apply.
Certain sanctions have already been suspended
For the already applicable suspension of certain sanctions, see here. It should also be noted that, in view of the situation in Iran under Regulation (EU) No 359/2011, restrictive EU measures against listed persons, organisations and institutions have so far remained unchanged.In view of the complexity of foreign trade law, a successful Iran business absolutely requires specialized legal advice