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Financial Services Law Insights and Observations

Preliminary Framework Agreed Upon to Reduce Iran's Nuclear Program

Sanctions China

Federal Issues

On April 2, the United States, along with the U.K., France, Germany, Russia, China, and the EU (the “P5+1”), agreed with Iran on a Joint Comprehensive Plan of Action (“JCPOA”).  The JCPOA is a preliminary framework to reduce Iran’s nuclear program, and details key parameters to provide the foundation upon which a final JCPOA is intended to be agreed by June 30, 2015. The framework includes five key components: (i) Enrichment, (ii) Inspections and Transparency, (iii) Reactors and Reprocessing, (iv) Sanctions Relief, and (v) Phasing. In particular, the sanctions relief will not be immediate and, instead, linked to verifiable measures Iran takes with respect to its commitments under the JCPOA.   In addition, sanctions relief is specific to a suspension of nuclear-related sanctions.  Importantly, the structure of such sanctions will remain in place, allowing for a “snap-back” of sanctions in the event of significant non-performance.  U.S. sanctions with respect to terrorism, human rights abuses and ballistic missiles will remain in place against Iran.