IRAN SANCTIONS – UPDATE

On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus (e.g. no U.S. persons, no U.S.-origin goods, or U.S. dollar payments). As discussed in our earlier blog post, the first batch of sanctions was reimposed on 6 August  and the second batch will become effective 5 November. On 5 November, the United States will re-impose the following secondary sanctions: Sanctions on Iran’s port operators and shipping and shipbuilding sectors, including IRISL; Sanctions on petroleum-related transactions, including the purchase of petroleum, petroleum products or petrochemicals from Iran; Sanctions on foreign financial institutions who engage with the Central…

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