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An Overview of the Joint Comprehensive Plan of Action

(163 Ratings)

Produced on: October 05, 2016

Course Format On Demand Audio

Taught by


Course Description

Time 62 minutes
Difficulty Beginner

On July 14, 2015, after more than 20 months of negotiations on Iran’s nuclear program, the P5+1 (China, France, Germany, Russia, the United Kingdom, and the United States), the European Union and Iran reached an agreement on the Joint Comprehensive Plan of Action (JCPOA). On January 16, 2016, a milestone referred to as “Implementation Day,” Iran received far-reaching economic and financial sanctions relief after meeting key nuclear commitments set out in the JCPOA. This sanctions relief is likely to have profound implications for the global economy, potentially releasing billions of dollars of assets and permitting Iranian oil to be sold on the international market. However, certain important U.S. and EU restrictions remain. For instance, the overwhelming majority of U.S. primary sanctions are still in force following Implementation Day and, until October 2023, U.S. suspended sanctions against Iran will remain on the books ready to be re-imposed quickly through the so-called “snapback” mechanism. Moreover, Iran remains an indeterminate environment for foreign investors, entailing certain legal and political risks and uncertainties, especially as Iran’s legal system has largely been untested by foreign investors. These limitations will lead to a number of challenges for sanctions compliance and business operations as investors and businesses seek opportunities related to Iran.

Join Anahita Thoms for a discussion of these issues. Anahita Thoms is a counsel in Freshfields Bruckhaus Deringer’s dispute resolution practice and a Group Leader for its Global Sanctions and Trade Team. After serving for three consecutive terms as a Vice-Chair of the Export Controls and Economic Sanctions Committee of the ABA (Section of International Law), Anahita was appointed Chair in 2016.

Learning Objectives:

  1. Gain a comprehensive understanding of the Iran sanctions landscape following the agreement on the Joint Comprehensive Plan of Action, with emphasis on the U.S. and EU sanctions regimes
  2. Identify key compliance issues when considering business opportunities in Iran under the remaining U.S. and EU sanctions regimes and learn strategies for risk mitigation
  3. Identify non-sanctions related challenges when investing in the Iranian market, including how to approach uncertainties vis-à-vis the Iranian legal system, which has largely not been tested by foreign investors
  4. Forecast milestones related to JCPOA implementation, including potential obstacles to implementation and their consequences


Anahita Thoms

Freshfields Bruckhaus Deringer

Anahita focuses her practice on global investigations, in particular in the field of international trade law, including sanctions and export control, and data protection law. She has significant experience advising on compliance programs, accompanying global internal and external investigations and self-disclosures.‎ She has also gained considerable experience in the area of excise tax, in particular energy and electricity tax fraud investigations, closely collaborating with the competent authorities.‎ Clients, particularly in the manufacturing, energy and financial sectors, rely on Anahita for her experience handling complex issues that arise in the intersection of US and EU trade and data protection laws.

She has published widely on topics related to European, German and US trade law, in particular on sanctions and export control law issues, excise tax, and data protection. Inter alia she is co-author of the export control law commentary "Dorsch", has written about the economic sanctions imposed on Russia in the article “Same but different: the U.S. and EU capital market sanctions on Russia", assessed the implications of US export control reform in the article "High Walls Around a Small Yard"‎, and authored the chapter titled "Extraterritoriality and Foreign Blocking Statues" in the American Bar Association's (ABA) "Export Controls & Economic Sanctions" handbook. She is also the co-author of the book "Energiesteuern in der Praxis‎"‎, and discussed the challenges European companies face in U.S. investigations in the New York Law Journal article "‎U.S. Investigations and EU Data Privacy Regime". Anahita has given several interviews to German newspapers on trade law developments, such as to the newspaper Börsenzeitung on the nuclear deal with Iran.‎

Anahita also regularly speaks at conferences and seminars on these topics, such as serving as a speaker at several ABA panels alongside senior US officials in New York and Washington DC and participating on roundtables on EU and US sanctions and export control law in Hong Kong and Singapore.

After serving for three consecutive terms as a Vice-Chair of the Export Controls and Economic Sanctions Committee of the ABA (Section of International Law), Anahita has been appointed Chair in 2016.


Julie A. B.

A well-informed speaker intimately familiar with this topic effectively elucidates the Iran sanctions landscape following the agreement on the JCPoA; highlights the United States and European Union sanctions regimes; addresses significant compliance issues; explains the profound consequences for the global economy; relates important compliance issues concerning business and investing opportunities; conveys assorted challenges when investing in the Iranian market; and offers tips on how to tackle the uncertainties associated with the Iranian legal system.

Russell B.

Excellent presentation ! Difficult subject matter presented in a easily understood manner. Russell Brahm

Kevin M.

Very interesting topic

Kevin J.

good intro to new topic

Francis M.

Very good presentation.

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