It is important to note that "Adoption Day" should not be confused with "Implementation Day" and that the sanctions remain in place until they are lifted by the Secretary of State. The waivers and findings, as well as the lifting of nuclear-related sanctions, announced by the Secretary of State (sections 17.1-17.2 of Annex V of the JCOPA) do not go into effect and will not occur until the Secretary of State confirms that Iran has implemented the nuclear-related measures specified in the JCPOA as verified by the International Atomic Energy Agency (IAEA). For a comprehensive review of the waiver provisions, please visit the JCPOA Contingent Waivers page on the Department of State website. Secretary of State issued certain waivers applicable to specific provisions and persons subject to the provisions of the IFCA. In accordance with the Memorandum issued by President Obama relating to Adoption Day, the U.S. We previously reported on the JCPOA in our July 15, 2015, Duane Morris Alert.
On October 18, 2015, President Obama issued a Presidential Memorandum preparing for the implementation (Implementation Day) of the Joint Comprehensive Plan of Action of J(JCPOA) entered into among the United States and other negotiating parties and Iran regarding Iran's nuclear programs and the lifting of certain sanctions imposed by both the United States (Iran Freedom and Counter-Proliferation Act of 2012 IFCA) and other countries-as well as by UN resolutions-that are now in place.
commitments with respect to sanctions under the Joint Comprehensive Plan of Action. Prior to Implementation Day, OFAC intends to publish on its website detailed guidance and information on the implementation of the U.S.
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