Pursuant to the conclusion of the JCPOA on July 14, 2015, between Iran and the 5+1 powers, nuclear-related sanctions applied by the US against Iran shall be lifted. However, such US sanctions would be terminated against non-US persons only.
Section 4 of the JCPOA states, "The sanctions that the United States will cease to apply, and subsequently terminate, or modify to effectuate the termination of, pursuant to its commitment under Section 4 are those directed towards non-U.S. persons." (see Footnote 6, Section 4 of the JCPOA). This point is repeated in Section 7.1 of the JCPOA, and other sections, reiterating the same.
The definition of non-US person, for the purposes of Sections 4 and 6-7 of the JCPOA which contain lifting of US nuclear-related sanctions, is provided in Footnote 6, in Section 4, as follows:
"For the purposes of Sections 4 and 6-7 of this JCPOA, the term “non-U.S. person” means any individual or entity, excluding (i) any United States citizen, permanent resident alien, entity organised under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States, and (ii) any entity owned or controlled by a U.S. person. For the purposes of (ii) of the preceding sentence, an entity is “owned or controlled” by a U.S. person if the U.S. person: (i) holds a 50 percent or greater equity interest by vote or value in the entity; (ii) holds a majority of seats on the board of directors of the entity; or (iii) otherwise controls the actions, policies, or personnel decisions of the entity. U.S. persons and U.S.-owned or -controlled foreign entities will continue to be generally prohibited from conducting transactions of the type permitted pursuant to this JCPOA, unless authorised to do so by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)."