President Trump ceased the Iran Deal- sanctions were immediately snapped back into place!-- What does that mean?
In conjunction with this announcement,the President issued a National Security Presidential Memorandum (NSPM) directing the Secretary of State and the Secretary of the Treasury to prepare immediately for the reimposition of all of the U.S. sanctions lifted or waived in connection with the JCPOA, to be accomplished as expeditiously as possible and in no case later than 180 days from the date of the NSPM.
Over the next few months, sanctions being re-imposed will have a wind-down period of either 90 days or 180 days.
Which sanctions will be re-imposed after the 90-day wind-down period ending on August 6, 2018?
After the 90-day wind-down period ends on August 6, 2018, the U.S. government will reimpose the following sanctions that were lifted pursuant to the JCPOA, including sanctions on associated services related to the activities below:
- Sanctions on the purchase or acquisition of U.S. dollar banknotes by the Government of Iran.
- Sanctions on Iran’s trade in gold or precious metals.
- Sanctions on the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial processes.
- Sanctions on significant transactions related to the purchase or sale of Iranian rials, or the maintenance of significant funds or accounts outside the territory of Iran denominated in the Iranian rial.
- Sanctions on the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and vi. Sanctions on Iran’s automotive sector.
In addition, following the 90-day wind-down period that ends on August 6, 2018, the U.S. government will revoke the following JCPOA-related authorizations under U.S. primary sanctions regarding Iran:
- The importation into the United States of Iranian-origin carpets and foodstuffs and certain related financial transactions pursuant to general licenses under the Iranian Transactions and Sanctions Regulations.
- Activities undertaken pursuant to specific licenses issued in connection with the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services.
- Activities undertaken pursuant to General License I relating to contingent contracts for activities eligible for authorization under the JCPOA SLP.
Which sanctions will be re-imposed after the 180-day wind-down period?
Following the 180-day wind-down period ending on November 4, 2018, the U.S. government will re-impose the following sanctions that were lifted pursuant to the JCPOA, including sanctions on associated services related to the activities below:
- Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines, South Shipping Line Iran, or their affiliates.
- Sanctions on petroleum-related transactions with, among others, the National Iranian Oil Company, Naftiran Intertrade Company, and National Iranian Tanker Company, including the purchase of petroleum, petroleum products, or petrochemical products from Iran.
- Sanctions on transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions under Section 1245 of the National Defense Authorization Act for Fiscal Year 2012.
- Sanctions on the provision of specialized financial messaging services to the Central Bank of Iran and Iranian financial institutions described in Section 104(c)(2)(E)(ii) of the Comprehensive Iran Sanctions and Divestment Act of 2010
- Sanctions on the provision of underwriting services, insurance, or reinsurance
- Sanctions on Iran’s energy sector.