Iran Sanctions – August Deadline

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-US persons even where there is no US nexus. Depending on the economic sector targeted, the particular sanction will be imposed either 90 or 180 days after the President’s announcement (6 August and 5 November, respectively). Implementation of the first batch of sanctions is rapidly approaching. On 6 August, the United States will re-impose the following secondary sanctions that were lifted as part of the JCPOA: Sanctions on the purchase or acquisition of U.S. dollar banknotes by the Government of Iran; Sanctions on Iran’s trade in gold or precious metals; Sanctions on the direct and indirect sale, supply, or…

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