Lifting of Certain Sanctions under the Joint Comprehensive Plan of Action (JCPOA) 20 January 2016 No.15-016 Download PDF (144KB) This Circular advises Members of the current position on their insurance cover arrangements with the regard to the partial lifting of Iran sanctions under the Joint Comprehensive Plan of Action (JCPOA). Lifting of EU and U.S. Secondary Sanctions ‘Implementation Day’ under the JCPOA relating to the curtailment of Iranian nuclear activities was announced on Saturday 16 January 2016.  This has triggered the general lifting of the EU sanctions, save where there are prior authorisation requirements in respect of certain materials, which have targeted amongst other things maritime trade with Iran together with the insurance of vessels engaged in such trade and the provision of insurance and reinsurance cover to Iranian vessels and entities. At the same time there has been a partial lifting of U.S. secondary sanctions measures and prohibitions i.e. measures and prohibitions on non-U.S. persons and entities. Secondary sanctions will, however, continue to apply to non-U.S. persons where, for example, they knowingly facilitate significant financial transactions with or provide material or certain other support to those Iranian or Iran-related persons that remain or are placed on the SDN list. U.S. Primary Sanctions However, the U.S. Administration has not repealed or relaxed certain primary U.S. prohibitions on U.S. entities engaging with Iranian businesses and persons. Prohibitions on U.S. financial institutions, U.S. Dollar transactions, and the provision of insurance by U.S. insurers and reinsurers will remain in place. Despite the lifting of sanctions announced on Implementation Day, U.S. persons will continue to be generally prohibited from exporting goods, services, or technology directly or indirectly to Iran, including extending insurance cover to, or paying claims involving, Iran, with the exception of transactions that are exempt or a