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Iran Nuclear-Related Sanctions to be Re-Imposed

May 10, 2018

President Trump has announced that the U.S. will cease participation in the Joint Comprehensive Plan of Action (JCPOA) and begin to re-impose U.S. nuclear-relation sanctions against Iran, following a wind down period.

The Office of Foreign Assets Control (OFAC) expects that all the U.S. nuclear-related sanctions that had been lifted under the JCPOA will be re-imposed and in full effect.

90 or 180 day wind-down period? What sanctions will go into effect, and when?

The 90-day wind down period ends on August 6, 2018.

Sanctions will be re-imposed for the following:

  1. The purchase or acquisition of U.S. dollar banknotes by the Government of Iran;
  2. Iran’s trade in gold or precious metals;
  3. The direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial processes;
  4. 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;
  5. The purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and
  6. Iran’s automotive sector.

In addition, the U.S. will revoke the following JCPOA-related authorizations under U.S. primary sanctions regarding Iran:

  1. The importation into the U.S. of Iranian-origin carpets and foodstuffs and certain related financial transactions pursuant to general licenses under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR);
  2. Activities undertaken pursuant to specific licenses issued in connection with the Statement of Licensing Policy (SLP) for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services (JCPOA SLP); and
  3. Activities undertaken pursuant to General License I relating to contingent contracts for activities eligible for authorization under the JCPOA SLP.

The 180-day wind-down period ending on November 4, 2018.

Sanctions will be re-imposed for the following:

  1. 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;
  2. 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;
  3. Transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions under Section 1245 of the National Defense Authorization Act for Fiscal Year 2012 (NDAA);
  4. The provision of specialized financial messaging services to the Central Bank of Iran and Iranian financial institutions described in Section 104(c)(2)(E)(ii) of the Comprehensive Iran Sanctions and Divestment Act of 2010 (CISADA);
  5. The provision of underwriting services, insurance, or reinsurance; and
  6. Iran’s energy sector.

In addition, effective November 5, 2018, the U.S. government will revoke the authorization for U.S.-owned or -controlled foreign entities to wind down certain activities with the Government of Iran or persons subject to the jurisdiction of the Government of Iran that were previously authorized pursuant to General License H.

Furthermore, no later than November 5, 2018, the U.S. government will re-impose, the sanctions that applied to persons removed from the List of Specially Designated Nationals and Blocked Persons (SDN List) and/or other lists maintained by the U.S. government on January 16, 2016.

Persons engaging in these activities should take the steps necessary to wind down those activities by August 6, 2018; or November 4, 2018, depending on the activity, to avoid exposure to sanctions or an enforcement action under U.S. law.

OFAC has updated their Frequently Asked Questions (FAQ) on Iran sanctions.

Specific questions may be directed to OFAC’s hotline at 1-800-540-6322, or 1-202-622-2490, or via email to [email protected].

If you have any general questions regarding the re-imposition of U.S. sanctions for Iran, Livingston can help! Please contact either your Livingston account manager or our regulatory affairs group at [email protected].