The Iran sanctions landscape is poised to change in early 2016, but US persons and US companies will see far fewer opportunities than their European counterparts.

On July 14, 2015, the P5+1 countries (the United States, United Kingdom, France, Russia, China and Germany) and Iran reached a historic nuclear non-proliferation agreement called the Joint Comprehensive Plan of Action (the Agreement). In line with the framework announced in April 2015 (as discussed in our previous client alert dated April 27, 2015), the Agreement provides for the termination of most European Union (EU) and UN sanctions and significantly more modest changes to the longstanding US embargo against Iran. The bulk of these changes will likely take effect in early 2016, after the International Atomic Energy Agency (IAEA) certifies that Iran has met certain of its nuclear-related commitments and other milestones have been reached.