Iran

Commerce Department Establishes Standard Policy for Questionnaire Extensions in AD/CVD Proceedings

The Department of Commerce issued a new policy to create uniform filing deadline extensions in antidumping duty and countervailing duty proceedings. Overall, the policy will decrease the amount of time received in extension requests for initial and supplemental questionnaires. The specific policy updates include

Tariff News

IEEPA Tariffs on China, Mexico, and Canada

We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused until March 10, and only the 10% tariffs on China are in effect.

Removal and

President Trump issued an Executive Order on September 21, 2020 which, effective immediately, imposes secondary sanctions on the transfer and sale of certain conventional arms shipments and the supply of related services to Iran by non-U.S. persons.  This Executive Order follows the current administration’s failed effort to reinstate sanctions and a conventional arms embargo by

The United States is formally demanding that the United Nations (U.N.) reimpose sanctions on Iran for its failure to meet commitments to limit its nuclear program set forth under the Joint Comprehensive Plan of Action (JCPOA).  U.N. sanctions on Iran were lifted in 2015 as part of the terms of the JCPOA, which included the United States, European Union, France, Germany, the United Kingdom, Russia, and China as signatories.  The U.S. formally withdrew from the JCPOA in 2018 and reinstated sanctions on Iran.

In a January 10th Executive Order, President Trump expanded sanctions on Iran after a ballistic missile attack on two American military bases in Iraq.  Executive Order 13902 expands secondary sanctions on Iran to include “significant” or “material” support transactions between non-U.S. persons and Iran’s construction, mining, manufacturing, and textiles sectors as potentially sanctionable

On April 21, 2019, the White House announced that President Trump has decided not to reissue the Iranian oil sanctions waivers, called “Significant Reduction Exceptions” (SREs) when they expire in early May. The White House statement explained that “[t]his decision is intended to bring Iran’s oil exports to zero, denying the regime its principal source of revenue.”

On November 5, 2018, the United States fully reimposed sanctions against Iran as part of its decision to withdraw from the Iran nuclear deal, also known as the Joint Comprehensive Plan of Action (“JCPOA”).  President Trump announced the decision to withdraw on May 8, 2018, thus beginning the “wind-down” period for businesses to withdraw from Iran. 

President Trump signed a new Executive Order on August 6, 2018, titled “Reimposing Certain Sanctions with Respect to Iran”. The Executive Order was timed to coincide with the last day of the 90-day wind-down period established for activities associated with certain sanctions relief authorized by the Joint Comprehensive Plan of Action (“JCPOA”).  As a result, the first round of sanctions against Iran will become effective at 12:01 a.m. on August 7, 2018.

On June 27, 2018, the U.S. Department of  Treasury’s Office of Foreign Assets Control (“OFAC”) officially revoked General Licenses H and I.  General License H previously allowed foreign owned or controlled subsidiaries of U.S. companies to engage in limited transactions with Iran that would have otherwise been prohibited under the Iranian Transactions and Sanctions Regulations (the “ITSR”).  General License I previously allowed U.S. persons to negotiate and enter into contingent contracts for exports and reexports to Iran of commercial passenger aircraft and related parts and services that were eligible to potentially receive specific licenses under the Iran Nuclear Deal, otherwise known as the Joint Comprehensive Plan of Action (the “JCPOA”).  OFAC previously advised that these revocations would be forthcoming in May, when President Trump formally announced his decision to withdraw from the JCPOA.

President Trump announced today, May 8, 2018, that the United States will withdraw from the Iran Nuclear Deal and will begin reimposing previously waived sanctions on Iran.  The deal, formally known as the Joint Comprehensive Plan of Action, or JCPOA, was signed by the U.S. in July 2015 along with China, France, Germany, Russia, the United Kingdom, the European Union and Iran. The White House issued a statement which explained that “President Trump is terminating United States participation in the JCPOA, as it failed to protect America’s national security interests.”