United States Takes Steps to Re-Impose Certain Primary Sanctions on Iran: Treasury Department Revokes JCPOA-Related General Licenses Under the ITSR, Amends the ITSR, and Publishes Revised FAQs Related to Reinstatement of Elements of the Pre-JCPOA Primary Sanctions Regime

Sullivan & Cromwell LLP - June 28, 2018

On June 27, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took actions to implement the President Trump’s decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with respect to Iran and to re-impose the U.S. nuclear-related sanctions targeting Iran that were lifted under the JCPOA. Most significantly, OFAC revoked General License H (“GL H”), which had granted sanctions relief to foreign entities owned or controlled by U.S. persons, and amended the Iranian Transactions and Sanctions Regulations to authorize activities ordinarily incident and necessary to the wind-down of activities that had been authorized under GL H through November 4, 2018. This means that, except for authorized wind-down activities, non-U.S. persons owned or controlled by U.S. persons no longer may rely on GL H and must now comply with the general prohibitions on dealings with Iran that apply to U.S. persons.