With the announcement by the P5+1 and Iran of a framework agreement aimed at resolving the issue of Iran’s disputed nuclear program, we’ve seen a great deal of speculation from the media about the impact of sanctions relief on the Iranian economy. Headlines such as “Billions up for grabs” and “Iran deal could unlock huge economic potential” create the impression that the minute John Kerry’s pen hits the paper of a nuclear agreement, the rush into Iran is on and those who sit back will miss out on the opportunity of a lifetime. Just the prospect of certain sanctions on Iran being lifted has sent the Tehran Stock Exchange up over 6% in the past few days. No sanctions, limitless growth, what’s not to love? It almost makes me want to reinvest all of my (meager) savings. One can only imagine how those with personal ties to Iran feel about this potential opportunity.

While you may never have thought high school English, Shakespeare in particular, would have any real-world application, you were wrong. In reality, Shakespeare has left some very sound advice for U.S. persons considering investing in Iran, deal or no deal.

All that glitters is not gold.

This may be disappointing news to those who have already concocted elaborate plans about what to do with their newfound riches, but the reality is that at least for the foreseeable future, the restrictions on U.S. persons’ dealings with Iran will likely remain unchanged. The U.S. embargo, established pursuant to Executive Orders 12959 and 13059, was implemented for reasons unrelated to Iran’s nuclear program and it is highly unlikely that any comprehensive agreement will do much to alter the Iranian Transactions and Sanctions Regulations (“ITSR”).

So even if there is an Iran deal, 31 C.F.R. § 560.207 is not going anywhere. In case you’re not familiar with § 560.207, this section of the ITSR prohibits new investment by U.S. persons in Iran or in property owner or controlled by the Government of Iran. New investment as defined by § 560.316 can mean anything from purchasing stock, to depositing money in a bank account, to loaning money to your cousin in Tehran with the expectation that it will be repaid. Yes, investing in the Tehran Stock Exchange counts, no matter how fast it appears to be growing.

U.S. enforcement agencies may also be looking to counter any perception that a deal has lessened their commitment to policing the remaining sanctions. OFAC is unlikely to look the other way when it comes to blatant violations such as engaging in prohibited new investment. Indeed, following the announcement of the framework agreement, the following warning appeared on OFAC’s Iran page:

As of today and until a JCPOA is concluded, other than the sanctions relief provided under the JPOA, all U.S. sanctions remain in place and will continue to be vigorously enforced (emphasis added)

It should also be noted that given the broad interpretation of “willfulness” applied in past criminal enforcement cases (see U.S. v. Mousavi), it does not take much for the Justice Department to turn a civil violation into a criminal one.

At the end of the day, the best approach should that the one advised by an SEC official in 2003: