President Trump Ends U.S. Participation in JCPOA, Reinstitutes Sanctions against Iran

President Donald J. Trump declared that the U.S. would end its involvement in the Joint Comprehensive Plan of Action (“JCPOA”) and ordered the reinstitution of U.S. sanctions against Iran.

The President ordered the Secretary of State and the Secretary of the Treasury to “re-impose all United States sanctions lifted or waived in connection with the JCPOA.” The Department of the Treasury Office of Foreign Assets Control (“OFAC”) will (i) “revoke, or amend, as appropriate” all general and specific licenses that were issued in connection with the JCPOA, (ii) issue new authorizations to ensure the wind-down of transactions and activities that relate to the removed or amended general and specific licenses, and (iii) institute pre-JCPOA sanctions at the end of the 90-day and 180-day wind-down periods. OFAC provided additional FAQs to provide guidance on the re-imposition of sanctions.