On November 5, 2018, the U.S. government reimposed the remaining sanctions on Iran that were previously lifted under the Joint Comprehensive Plan of Action (JCPOA) in 2016.  Treasury’s Office of Foreign Assets Control (OFAC) added over 700 Iranian entities, individuals, vessels, and aircrafts to the list of Specially Designated Nationals and Blocked Persons (“SDN List”), including scores of previously unlisted targets.  According to a statement from Treasury, these sanctions are “designed to disrupt the Iranian regime’s ability to fund its broad range of malign activities, and places unprecedented financial pressure on the Iranian regime to negotiate a comprehensive deal that will permanently prevent Iran from acquiring a nuclear weapon, cease Iran’s development of ballistic missiles, and end Iran’s broad range of malign activities.”

The new or reimposed SDN designations include nearly 250 persons and associated blocked property that had appeared on the so-called “EO 13599 list,” 50 additional Iranian banks and their subsidiaries, and over 400 additional affiliated targets in a range of sectors, including Iran’s shipping, energy, and aviation sectors, among others. OFAC has published a complete list of designated entities here.  Under the existing sanctions framework, foreign financial institutions and persons that facilitate or engage in transactions with designated entities are themselves potentially subject to U.S. sanctions restrictions.

As explained in a statement from the White House regarding the sanctions, existing humanitarian authorizations and exceptions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran also apply to yesterday’s SDN listings.

The Secretary of State also announced the issuance of significant reduction exemptions (SREs) that waive the imposition of certain sanctions with respect to certain countries that import Iranian oil. Secretary of State Mike Pompeo announced that SREs would be issued for countries including: China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey.

Iran responded to the reimposition of sanctions with air defense drills and a statement by President Hassan Rouhani that the nation faces a “war situation.” Leaders from the European Union have also released a statement declaring that they “deeply regret the reimposition of sanctions by the U.S.” and that the remaining parties of the JCPOA have committed to “protect[ing] European economic operators engaged in legitimate business with Iran.”

This latest round of sanctions follows a tweet by President Trump featuring a picture of himself with the words “Sanctions are Coming” superimposed across his chest. This photo was a play on an advertisement for the popular HBO series Game of Thrones, which features a picture of a lead character with the words “Winter is Coming.”  In a statement made to the New York Times, HBO indicated that it was “not aware of this messaging” and “would prefer our trademark not be misappropriated for political purposes.” According to the New York Times, although it is not yet clear whether the President will bring winter to the Iranian economy, “he is off to a strong start.”

More details on the new sanctions will be available in the days to come. More information can be found in a Fact Sheet released by the White House as well as in OFAC’s Frequently Asked Questions (FAQs).