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 May 2018 Guidance on Reimposing Certain Sanctions with Respect to Iran

On May 8, 2018, the President announced his decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) and to begin re-imposing the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief, following a wind-down period.  In conjunction with this announcement, the President issued National Security Presidential Memorandum-11 directing the U.S. Department of the Treasury and other Departments and Agencies to take the actions necessary to implement his decision.

Consistent with the President’s guidance, Departments and Agencies  implemented 90-day and 180-day wind-down periods for activities involving Iran that were consistent with the U.S. sanctions relief specified in the JCPOA.  To effectuate the wind-down periods, the State Department has issued the necessary statutory sanctions waivers for the duration of the relevant wind-down periods.  In addition, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has revoked, or amended, as appropriate, general and specific licenses issued in connection with the JCPOA.  OFAC also issued new authorizations to allow the wind down of transactions and activities that were authorized pursuant to the revoked or amended general and specific licenses. 
 
August 6, 2018, marks the final day of the 90-day wind-down period.  The President has issued Executive Order 13846 (E.O.) of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran” ,  which reimposes relevant provisions of five Iran sanctions E.O.s that were revoked or amended by E.O. 13716 of January 16, 2016.  Executive Order 13846 is effective at 12:01 a.m. eastern daylight time (EDT) on August 7, 2018, at which time the sanctions subject to the 90-day wind-down period will come into effect pursuant to Executive Order 13846 and, as appropriate, relevant statutory provisions that will no longer be within the scope of the waiver actions taken by the Secretary of State. 
 
In addition, certain wind-down general licenses (GLs) previously issued by OFAC expire at 11:59 p.m. EDT on August 6, 2018.  For detailed information regarding which GLs expire on August 6 and which sanctions are reimposed on August 7, see FAQ 1.2 of the Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the Join Comprehensive Plan of Action (JCPOA).
 
The 180-day wind-down period ends at 11:59 p.m. eastern standard time (EST) on November 4, 2018, and the remaining sanctions that had been lifted or waived pursuant to the JCPOA come back into full effect on November 5, 2018.  For information about which sanctions will be reimposed on November 5, 2018, see FAQ 1.3 of the Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the JCPOA.  OFAC will publish additional guidance with respect to the end of the 180-day wind-down period no later than November 4, 2018. 
 
OFAC has posted to its website updated additional frequently asked questions (FAQs) that provide guidance on the sanctions that are to be reimposed and the relevant wind-down periods.  In addition, OFAC has posted to its website FAQs relating to E.O 13846.
 
The U.S. government will continue to make aggressive use of its authorities to target Iran’s malign behavior. 
Last Updated: 11/5/2018 7:57 AM