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
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U.S. Seeks Snapback of U.N. Sanctions on Iran Despite Departure from Nuclear Deal
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.
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Trump Administration Expands Iran Sanctions to New Sectors in Recent Executive Order
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
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President Trump to End Sanctions Waivers for Iranian Oil
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.”
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U.S. Reimposes Tough Sanctions on Iran; More Designations to Come
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.
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United States Announces Re-imposition of First Round of Nuclear Sanctions on 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.
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OFAC Officially Revokes Iran General Licenses and Signals Aggressive Enforcement Posture
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.
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President Trump Announces Decision to Withdraw from Iran Nuclear Deal and Reimposition of Previously Waived Sanctions
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.”
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U.S. Commerce Department Rescinds Export Privileges for China’s ZTE
On April 15, 2018, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a denial order against ZTE Corporation and ZTE Kangxun Telecommunications Ltd. (collectively “ZTE”), effectively banning U.S. companies from providing components to ZTE because the company had failed to comply with the terms of a disciplinary agreement reached in March 2017 arising from violations of U.S. export control restrictions against Iran and North Korea. It is estimated that U.S. companies provide nearly 25-30 percent of the components used in ZTE products. ZTE’s U.S. subsidiary advertises that it has been ranked by independent industry analysts as the fourth-largest supplier of mobile devices in the U.S. overall and second-largest supplier of prepaid devices.
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President Trump Temporarily Extends Iran Nuclear Deal
President Donald Trump has announced that he will approve certain sanctions waivers necessary in order to preserve the Iran nuclear deal (JCPOA). In an official statement, the President indicated that this is the last such waiver he will issue and warned that “the United States will not again waive sanctions in order to stay in the Iran nuclear deal.”
President Trump called on Congress to enact legislation addressing Iran and stated that the legislation should include the following critical components:
- The legislation must require Iran to allow immediate inspections by international inspectors at all nuclear sites.
- The legislation must “ensure that Iran never even comes close to possessing a nuclear weapon”.
- The legislation “must have no expiration date.” President Trump stated that “My policy is to deny Iran all paths to a nuclear weapon – not just for ten years, but forever.”
- The legislation must subject Iran’s long-range missile program to the same sanctions imposed on its nuclear weapons program.
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OFAC and State Department Update Iran and Russia Sanctions Under Countering America’s Adversaries Through Sanctions Act
The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has amended its Global Terrorism Sanctions Regulations (GTSR) in order to impose additional sanctions on Iran’s Islamic Revolutionary Guard Corps (IRGC) within the timeline required by the Countering America’s Adversaries Through Sanctions Act (CAATSA). Effective October 31, 2017, persons and entities that OFAC has designated as officials, agents, or affiliates of the IRGC remain subject to secondary blocking sanctions which continue to prohibit them from engaging in activity with US and non-US persons and, in addition, these amendments to the GTSR now impose new sanctions to prohibit the designated IRGC affiliates from receiving humanitarian donations and other forms of assistance. OFAC has provided a list of the IRGC affiliates subject to these amendments here.
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