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Meltdown of the Iran Nuclear Deal—Sanctions Update

On May 8, 2018, President Donald Trump announced that the United States would no longer participate in the Joint Comprehensive Plan of Action (JCPOA), the international agreement regarding Iran’s nuclear activities and sanctions imposed on Iran that was entered into in July 2015. The Treasury Department’s Office of Foreign Asset Control quickly issued a frequently asked questions bulletin explaining how the U.S. will re-impose sanctions that had been lifted pursuant to the JCPOA. The U.S. withdrawal from the deal will occur over either a 90-day (ending August 6, 2018) or 180-day (ending November 4, 2018) wind-down period, depending on the type of activity at issue. Here are some key takeaways:

  1. Until the expiration of the applicable wind-down period, all prior guidance, waivers, and licenses effectively remain in place (though under temporary wind-down waivers).

  2. Non-U.S. persons owed payment for goods or services supplied to non-Iranian persons that were legal under the JCPOA can still receive payment even after expiration of the wind-down period provided such payments do not involve U.S. persons or the U.S. financial system.

  3. All persons removed from the SDN (Specially Designated Nationals) List under the deal will be re-designated as such by November 5, 2018. These persons and entities will be subject to secondary sanctions after that date. Secondary sanctions are those targeting non-U.S. citizens and companies abroad that interface with the U.S. financial sector. This category of sanctions has been used particularly aggressively as it relates to Iran.

  4. Any specific or general licenses extended under the JCPOA will be revoked, including the licenses related to commercial aircraft sales and the importation of Iranian carpets and foodstuffs. Any applications still pending will be denied.

Because of the complexity of U.S. sanctions, individuals should confer with an attorney about the application of the new authority to their specific circumstances.