President Trump issued an Executive Order today re-imposing and, in some cases, expanding sanctions on Iran that had been lifted under the 2016 nuclear deal (the “JCPOA”), as today marked the end of the first “wind-down” period of 90 days following the President’s May 8 announcement that the US would no longer honor its sanctions commitments under the JCPOA. Some of the re-imposed sanctions will be effective tomorrow, August 7; others will come back into effect following the second (180-day) wind-down period ending November 4. In addition, OFAC issued additional answers to frequently asked questions on Iran sanctions, including guidance on the circumstances in which payments from Iranian parties can be received after the end of the wind-down periods. These actions are largely consistent with the President’s May 8 announcement and the earlier guidance that had been issued by OFAC on the re-imposition of Iran sanctions.
Effective August 7, the following sanctions that were lifted pursuant to the JCPOA, have been reimposed, including sanctions on certain support for and services related to the activities below: Continue Reading