On May 8, 2018, U.S. President Donald Trump announced that the U.S. will cease participation in the Joint Comprehensive Plan of Action (JCPOA), and will re-impose the nuclear-related sanctions that were lifted under the JCPOA. This process will take place following a wind-down period.

To begin the process of bringing the sanctions back into effect, the State Department issued statutory sanctions waivers to allow for the 90-day and 180-day wind down periods for activities involving Iran sanctions relief specified in the JCPOA. Additionally, the Department of Treasury’s Office of Foreign Assets Control (OFAC) expects “…to revoke, or amend, as appropriate, general and specific licenses issued in connection with the JCPOA” and to “…issue new authorizations to allow the wind down of transactions and activities that were authorized pursuant to the revoked or amended general and specific licenses.”

Additionally, OFAC issued FAQs to provide guidance on the sanctions that will be re-imposed and the associated wind-down periods.

The applicable sanctions will come back into full effect at the end of the 90-day and 180-day wind down periods.

The OFAC notice may be found here:

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

The FAQs may be found here:

https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_winddown_faqs.pdf