On November 5, 2018, the U.S. government fully re-imposed sanctions on Iran as a result of the cessation of the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) (see Trump and Trade Update dated May 8, 2018). November 5 marked the end of the 180-day wind-down period for activities that had previously been allowed with Iran under the JCPOA. This deadline, along with the August 6, 2018 re-imposition of other sanctions toward Iran (see Trump and Trade Update dated August 6, 2018), now means that all U.S. sanctions lifted or waived in connection with the JCPOA have been re-imposed and are in full effect. On Friday November 2, 2018, Secretary of State Michael Pompeo and Secretary of the Treasury Steven Mnuchin held a special briefing to address the “snapback” of these sanctions on Iran’s energy, shipping, banking and shipbuilding industries that were lifted as part of the Iran nuclear deal.

Pompeo stated that “these sanctions hit at the core areas of Iran’s economy. They are necessary to spur changes we seek on the part of the regime.” Mnuchin announced: “The Treasury Department will add more than 700 names to our list of blocked entities. This includes hundreds of targets previously granted sanctions relief under the JCPOA, as well as more than 300 new designations.” The United States has temporarily granted eight countries (China, India, Italy, Greece, Japan, South Korea, Taiwan and Turkey) an “exemption” for specific circumstances dealing with the limited procurement of Iranian crude oil. Pompeo indicated, however, that “we will continue negotiations to get all the nations to zero.”

In a press release issued by the Office of Foreign Assets Control (OFAC), Mnuchin further stressed that “Treasury’s imposition of unprecedented financial pressure on Iran should make clear to the Iranian regime that they will face mounting financial isolation and economic stagnation until they fundamentally change their destabilizing behavior. Iran’s leaders must cease support for terrorism, stop proliferating ballistic missiles, end destructive regional activities, and abandon their nuclear ambitions immediately if they seek a path to sanctions relief.”

Sanctions previously lifted under the JCPOA have been re-imposed on the following industries, companies and organizations that have now been placed on the OFAC Specially Designated Nationals and Blocked Persons (SDN) List:

  • More than 70 Iran-linked financial institutions, including their foreign and domestic subsidiaries.
  • Iran’s Islamic Republic of Iran Shipping Lines (IRISL) and National Iranian Tanker Company (NITC), including 65 IRISL subsidiaries and associated individuals.
  • The Atomic Energy Organization of Iran (AEOI) as well as 23 AEOI subsidiaries and associated individuals.
  • Iran Air (the national airline of Iran) and 67 aircraft operated by Iran Air.

In a fact sheet issued by the White House, the Trump administration stated that sales of food, agricultural commodities, medicine and medical devices will continue to remain exempt from the sanctions.

For further information, the OFAC has published the full list of entities added to the SDN List and updated its frequently asked questions concerning the re-imposition of these sanctions.