US WITHDRAWAL FROM JCPOA IRAN DEAL – NEW US SANCTIONS IMMINENT

As all media have been reporting, President Trump announced on 8th May that he was pulling the US out of the JCPOA and would be imposing new, tougher sanctions.

OFAC FAQ UPDATED

On 8th May, OFAC published updated FAQ with additional questions.  These provide further guidance on the changes.  OFAC says in particular that, to implement the President’s direction, the Departments of State and US Treasury will take steps necessary to establish a 90-day and a 180-day wind-down period for activities involving Iran that were consistent with the US sanctions relief provided for under the JCPOA.

https://www.treasury.gov/resource-center/sanctions/Programs/Pages/iran.aspx

After 6th August, the US will re-impose the following sanctions –

  • Sanctions on the purchase or acquisition of US dollar banknotes by the Government of Iran;
  • Sanctions on Iran’s trade in gold or precious metals;
  • Sanctions on the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as aluminium and steel, coal, and software for integrating industrial processes;
  • Sanctions on 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;
  • Sanctions on the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt;
  • Sanctions on Iran’s automotive sector.
  • Revoking the exemption allowing the importation into the US of Iranian-origin carpets and foodstuffs and certain related financial transactions pursuant to general licenses under the Iranian Transactions and Sanctions Regulations;
  • Revoking the exemption allowing 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); and
  • Revoking the exemption allowing activities undertaken pursuant to General License I relating to contingent contracts for activities eligible for authorization under the JCPOA SLP.

After 8th November, the US will impose the following –

  • 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;
  • Sanctions on the provision of specialized financial messaging services to the Central Bank of Iran and Iranian financial institutions;
  • Sanctions on the provision of underwriting services, insurance, or reinsurance; and
  • Sanctions on Iran’s energy sector.

Also, no later that 5th November, other changes will be made, including the restoration to the US SDN sanctions lists of those persons and entities which have been removed following the JCPOA.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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