On July 14, 2015, negotiators from Iran, the EU, and the P5+1 countries —China, France, Russia, the United Kingdom, the United States, and Germany—announced that they had reached a consensus on the final text of the Joint Comprehensive Plan of Action (“JCPOA”) with Iran. In exchange for Iran’s commitment to scaling back its existing nuclear operations and developing a commercial nuclear program for exclusively peaceful purposes, the remaining parties committed to gradually lift UN Security Council (“UNSC”) sanctions, multilateral sanctions, and national sanctions related to Iran’s nuclear program. Despite this historic agreement, it is important to note that until Implementation Day—expected in four to nine months—restrictions remain in place. For example, restrictions on U.S. parties and foreign entities owned or controlled by U.S. parties conducting business with Iran remain virtually unchanged. Once the JCPOA is implemented, however, foreign entities owned or controlled by U.S. persons will be able to obtain licenses from the U.S. government to engage in activities with Iran permitted under the JCPOA. However, the parties agreed to maintain in force the limited sanctions relief set forth in the interim Joint Plan of Action from November 2013.