President Trump withdraws U.S. from Iran deal.

On May 8, President Trump withdrew U.S. participation in the Joint Comprehensive Plan of Action (JCPOA) and took action to reinstate and impose new sanctions on Iran.

In his memoranda the President refers to his January 12, 2018 outline to adjust flaws in the JCPOA by May 12th  and indicates that this withdrawal is a result of that change not taking place.  
The Memoranda directs the re-imposition of all United States sanctions lifted or waved by the JCPOA and will include those under “the National Defense Authorization Act for Fiscal Year 2012, The Iran Sanctions Act of 1996, The Iran Threat Reduction and Syria Human Rights Act of 2012, and the Iran Freedom and counter-proliferation Act of 2012.”
There will be a two phase "wind-down" period to be coordinated by the Secretary of State and the Secretary of the Treasury, 

“After the 90-day wind down period ends on August 6, 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:

  • The purchase or acquisition of U.S. dollar banknotes by the Government of Iran
  • Iran’s trade in gold or precious metals 
  • 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 
  • 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 
  • The purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt
  • 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, 31 C.F.R. part 560 (ITSR) 
  • 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 (JCPOA SLP) 
  • Activities undertaken pursuant to General License I relating to contingent contracts for activities eligible for authorization under the JCPOA SLP” 

“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 (IRISL), South Shipping Line Iran, or their affiliates
  • Sanctions on petroleum-related transactions with, among others, the National Iranian Oil Company (NIOC), Naftiran Intertrade Company (NICO), and National Iranian Tanker Company (NITC), 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 (NDAA)
  • 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 (CISADA)
  • Sanctions on the provision of underwriting services, insurance, or reinsurance
  • Sanctions on Iran’s energy sector.” 

Effective November 5, 2018 the U.S. government will revoke the authorization for U.S.-owned or -controlled foreign entities to wind down certain activities with the Government of Iran or persons subject to the jurisdiction of the Government of Iran that were previously authorized pursuant to General License H. In addition, it will re-impose the sanctions that applied to persons removed from the List of Specially Designated Nationals and Blocked Persons (SDN List) and/or other lists maintained by the U.S. government on January 16, 2016. 

Persons and companies engaged in the above listed activities should take the necessary steps to wind down their involvement to avoid sanctions or enforcement action. 

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