On Re-imposition of U.S. Sanctions Related to Iran

In connection with President Trump’s decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA), the Treasury Department issued an explanatory document on May 8 providing more detailed and concrete information about how the United States government will implement the President’s directive.  The implementation plan includes a 90-day and a 180-day wind-down period for activities involving Iran that were consistent with U.S. sanctions relief provided under JCPOA.  The 90-day period ends on August 6, 2018 and the 180-day period concludes on November 4, 2018.  The document helps answer general questions about the wind-down periods, outlines which specific sectors will be affected by re-imposed sanctions, and provides information about sanctions on individuals, Treasury licenses, and possible consequences for countries importing Iranian crude oil.  A link to the Treasury’s document is here:


Since the first wind-down period will end in the coming weeks, any companies that have ongoing dealings with Iran should review carefully those activities in light of the impending re-imposition of sanctions.

Additional information about U.S. policy to Iran: