On January 30, 2014, the Office of Foreign Assets Control (OFAC) published in the Federal Register Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan of Action (“JPOA”) Reached on November 24, 2013, Between the P5+1 and the Islamic Republic of Iran (“Guidance”). The P5+1 countries (China, France, Russia, the United Kingdom, the United States, and Germany) committed to provide Iran with limited, targeted, and reversible sanctions relief for a six-month period in return for Iran’s commitment to place meaningful limits on its nuclear program. With respect to U.S. commitments under the JPOA, the U.S. Departments of State and Treasury will implement sanctions relief relating to certain activities and associated services taking place exclusively during the six month period beginning on January 20, 2014, and ending on July 20, 2014 (“JPOA Period”). As discussed in more detail below, this relief almost exclusively applies to non-U.S. persons and is limited and temporary.

U.S. Commitments Under the JPOA -

Under the JPOA, the U.S. Government will not impose sanctions on non-U.S. persons involved in activities and associated services related to particular transactions in the petrochemical, auto, gold and precious metals, civil aviation, and crude oil industries in Iran. The U.S. Government also has committed to providing sanctions relief for purposes of facilitating humanitarian trade with Iran. Importantly, all transactions must occur exclusively during the JPOA Period. This means, for example, that a contract for eligible activities and services signed during the JPOA Period but performed after July 20, 2014, would not be eligible for sanctions relief....