Thinking about doing business with Iran?

During the early 1970s, engineering and architecture firms were profiting from the rapid investment in infrastructure improvements and building projects in Iran. That boom, of course, collapsed with the ouster of the Shah Mohammad Reza Pahlavi in February of 1979. Now some firms, including  American-owned entities, are anticipating that there might be new projects in Iran for foreign design firms.

On July 14, 2015, the five permanent members of the U.N. Security Council—China, France, Russia, the United Kingdom, and the United States—along with Germany reached a Joint Comprehensive Plan of Action (JCPOA) with Iran under which Iran will limit nuclear weapon development in exchange for the lifting of economic sanctions. Immediate relief from current U.S. sanctions, however, is not part of the agreement. Instead, the U.S. will begin to suspend its nuclear-related economic sanctions in a phased manner after verification of Iran’s implementation of the JCPOA by the International Atomic Energy Agency. And the U.S. retains the ability to revoke all sanctions relief if Iran fails to meet its nuclear obligations under the deal.

While the American design and construction industry, along with petroleum-related and other manufacturing entities, are contemplating opportunities in Iran, they will not materialize quickly. According to the law, all U.S. citizens and permanent resident aliens, persons and entities within the U.S., and U.S.-incorporated entities and their foreign branches continue to be prohibited from conducting transactions with Iran.

The lifting or additional relaxation of U.S. sanctions is not expected to occur until at least early 2016. The U.S. Department of Treasury’s Office of Foreign Assets is expected to provide additional guidance on the JCPOA in the near future. Until such guidance is available, key implementation details are unknown. However, the primary impact of sanctions relief under the JCPOA will be the expanded ability of non-U.S. entities and persons to enter into certain transactions with Iran. The U.S. has also agreed to license non-U.S. entities that are owned or controlled by U.S. persons to engage in such activities, and to permit imports of certain Iranian goods into the U.S. So rugs and caviar might be coming this way soon, but design expertise will not be exportable for quite a while.