Iran Sanctions: Opportunities and Challenges

RC: Could you provide an overview of the potential investment opportunities in Iran since the country reached an agreement over a nuclear framework deal with the P5+1 group?

de Bie: With regard to trade from the EU, there are various trade sectors in Iran which were not accessible under the EU measures but will become accessible once the Joint Comprehensive Plan of Action (JCPOA) is fully implemented. Most essential is probably the possibility to transfer funds between EU persons, entities or bodies, and Iranian persons, entities or bodies, without the requirement of authorisation or notification. Various potential investment industries were subject to EU restricted measures but will be open to trade once the measures are withdrawn. These industries are, for example, the oil, gas and petrochemical sector, the shipping, shipbuilding and transport sector, as well as the metals and software sector.

Bombach: In contrast to the EU sanctions relief that is expected upon implementation of the JCPOA, the US will maintain comprehensive sanctions prohibiting US entities and persons from dealings with Iran, with only certain limited exceptions. Currently permissible categories include exports of food and medicine, and there will be licences available for exports of commercial aircraft and parts and services related to commercial aircraft and safety of flight. Another area we are watching with interest is the expected US sanctions relief that will likely come in the form of general licences permitting certain activities by foreign subsidiaries of US companies to engage in activities ‘consistent with the JCPOA’. It remains to be seen exactly how this will be implemented and scope of permissible activities.

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