US Announces Withdrawal from JCPOA

Today, President Trump announced his intention to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and to impose the “highest level of economic sanctions” on Iran. The Office of Foreign Assets Control quickly thereafter published FAQs that discuss how the sanctions will be implemented. Importantly, the President’s announcement was not only limited to a decision not to renew a waiver under Section 1245 of the National Defense Authorization Act for Fiscal Year 2012 (NDAA) that was to expire on May 12, but also applies to all waivers covered by the JCPOA under other statutory provisions as well. The effect will be to “snap back” all of the sanctions that were previously in place prior to implementation of the JCPOA. There will, however, be a delayed implementation of the snap-back, with a 90-day wind down period for some activities, and a 180-day wind down for others. By August 6, 2018, the following sanctions will be…

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