Legal Alert - Implementation Day - Not Such a Special Day for U.S. Companies
by Brett W. Johnson and Sarah E. Delaney
After months of preparations, January 16, 2016 was “Implementation Day” – the day when the world’s sanctions on Iran were officially rolled back. On January 16, the International Atomic Energy Agency determined that Iran had significantly reduced its nuclear program. In exchange, under the agreement finalized with Iran and the United States last July, many Iranian assets were unfrozen, money could transfer between Iran and the European Union without special authorization, and the United States stopped its efforts to prevent Iranian crude oil sales.