Regulations UE n°2015/1861 and 2015/1862 of 18 October 2015, implementing the JCPOA, entered into force on January, 16, 2016 (Council decision (CFSP) 2016/37 of 16 January 2016, OJEU L 11 of 16 January 2016 p.1).

The main sanctions against Iran are lifted. Sector sanctions (financial sector, energy sector, Iranian transports) are lifted. However, the export of certain dual use items, software and raw or semi-finished metals will remain subject to control. The prohibition regime regarding military items and … as well as restrictions related to internal repression (restrictions to exports of equipment which may be used for internal repression, certain equipment, technology, monitoring or interception services as well as the provision of the required technical assistance) remains. Financial flows will not be subject anymore to prior notification or authorization requirements, unless they relate to the equipment listed here above.

Most freezing of funds are lifted. In particular, in France, only one bank remains subject to a freezing of funds, although some banks remain under administration by administrators.

The US have relaxed lifted secondary sanctions affecting non US persons in the same sectors as in the EU (financial sector, energy sector, Iranian transports, gold and precious metals) as well as in the automotive sector. The relaxation of certain sanctions also includes the possibility to obtain a general licence for non-US companies detained or controlled by US companies or a licence for the export of commercial passenger aircraft and related parts. US persons, including US companies, remain subject to comprehensive sanctions against Iran.