Iran sanctions – far-reaching exceptions can be approved

Transactions that violate the Iran sanctions can now be approved under certain conditions. The Joint Comprehensive Plan of Action (JCPOA) negotiated between Iran and the E3+3 states provides for various measures to gradually resolve the Iranian nuclear issue. Implementation of these measures requires the European Union (EU) to adopt regulations directly applicable in each Member State. In this context, Regulation (EU) No. 267/2012 was also adopted, according to which sanctioned acts may be permitted under certain conditions, subject to prior approval by the competent authority.

Activities directly related to the modification of two cascades of the[bold]fordo[/bold] plant for the production of stable isotopes, with the export of enriched[bold]uranium[/bold] Iran in quantities exceeding 300 kilograms in exchange for natural uranium or with the modernization of the[bold]arak[/bold] reactor may be authorised. In this context, activity means in particular delivery, sale, transfer, technical or financial assistance and investment.

In addition, the authorities may, on a case-by-case basis, authorise other activities related to the fulfilment of certain nuclear commitments set out in the JCPOA, necessary for the preparation of the implementation of the JCPOA or, as determined by the Sanctions Committee, compatible with the objectives of UN Resolution 2231 (2015).

Thus there is a possibility for the economy to get a basically sanctioned transaction approved that goes beyond the suspension of certain sanctions.

O&W Attorneys at Law will be happy to assist you comprehensively and competently with your application for a permit and with any further questions regarding your business in Iran.

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Lawyer Dr. Tristan Wegner

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