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:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_winddown_faqs.pdf
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:
- Presidential Memorandum of May 8, 2018, as signed by President Trump: https://www.whitehouse.gov/presidential-actions/ceasing-u-s-participation-jcpoa-taking-additional-action-counter-irans-malign-influence-deny-iran-paths-nuclear-weapon/
- Secretary Pompeo’s May 21 Iran speech: https://www.state.gov/e/eb/tfs/spi/iran/index.htm
- Treasury Department’s webpage where individuals can sign up for Iran sanctions email updates: https://www.treasury.gov/resource-center/sanctions/Programs/pages/iran.aspx
