On 8 May 2018, President Trump announced the withdrawal of the United States from the nuclear agreement with Iran—the Joint Comprehensive Plan of Action (JCPOA)—and initiated plans to re-impose sanctions on Iran that had been suspended under the terms of the 2015 agreement.
President Trump ordered the Secretary of State and the Secretary of the Treasury to prepare immediately for "the re-imposition of all of the U.S. sanctions lifted or waived in connection with the JCPOA," making clear that the snap-back of sanctions will be comprehensive and not, as some commentators had predicted, in piecemeal or partial fashion.
On 27 June 2018, the Treasury Department's Office of Foreign Assets Control (OFAC) announced key steps in that withdrawal. It revoked two general licenses issued pursuant to the JCPOA: General License H, which permitted foreign subsidiaries of U.S. companies to engage in certain business activities with Iran, and General License I, which permitted U.S. persons to enter into contingent contracts for activities permitted under the JCPOA. It also implemented wind-down periods for activities involving Iran that were commenced pursuant to JCPOA sanctions relief.
Our related client publication is available at:
- https://www.shearman.com/perspectives/2018/05/us-withdrawal-from-jcpoa
- https://www.shearman.com/perspectives/2018/06/non-us-companies-face-challenges-as-us-sanctions-on-iran-Return
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