Conclusion

Sanction relief is subject to “snap back” provisions in the JCPOA.  This essentially means that if Iran fails to comply with its continuing obligations under the JCPOA the sanctions can be immediately reinstated.   If you enter into any long term deals, this possibility must be considered. 

We cannot advise whether you can or cannot enter into a specific contract or transaction. However, in light of the above information, we recommend;  

1. Carrying out due diligence as to the nature of the transaction or contract, to make sure it is not related to any of the prohibited areas to which sanctions still apply;
2. Carrying out due diligence as to whether any of the parties to the contract or transaction are on a restricted list (such as the US SDN list or the EU lists);
3. Carry out due diligence to make sure none of the parties are a “front” for a restricted party;
4. Check if there is any US involvement, as their sanction regime is still applicable;
5. Check if there are any US banks involved, or if you will be paid via a US Bank as they will still be subject to the US sanction regimes and may not be able to process payments;  
6. Be mindful of the “snap back” provisions and be aware that the sanctions can be reinstated very quickly, for example, make sure there are proper termination provisions in any contract to deal with this;
7. If you require specific legal advice in relation to a specific contract or transaction, your legal advisors should be consulted.