United States Withdraws from the Joint Comprehensive Plan of Action with Iran: President Trump Announces Immediate Withdrawal from the Joint Comprehensive Plan of Action; Pre-JCPOA U.S. Sanctions Targeting Iran Will Be Fully Reinstated Following a Wind-Down Period

Sullivan & Cromwell LLP - May 9, 2018
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On May 8, 2018, President Trump announced his 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.  Following November 4, 2018, it is expected that the full panoply of the U.S. nuclear-related sanctions that had been lifted under the JCPOA will be re-imposed and in full effect.  New business that is contrary to the re-imposed sanctions will be sanctionable immediately upon re-imposition; 90-day and 180-day wind-down periods will be provided for business that pre-dates May 8, 2018.  Persons engaging in activity undertaken pursuant to the U.S. sanctions relief provided for in the JCPOA should take the steps necessary to wind down those activities by either August 6, 2018, or November 4, 2018, as applicable, to avoid exposure to sanctions or an enforcement action under U.S. law.