After the 180-day wind-down period ends on November 4, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities:
i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping Line Iran, or their affiliates (see, e.g., subsection 1(a)(iv) and section 5 of E.O. 13846 and section 1244(c)(1) of IFCA);
ii. Sanctions on petroleum-related transactions with, among others, NIOC, NICO, and the National Iranian Tanker Company (NITC), including the purchase of petroleum, petroleum products, or petrochemical products from Iran (see, e.g., subsections 1(a)(ii), 1(a)(iv), 2(a)(iii)-(a)(v), and 3(a)(ii)-(a)(iii) and sections 4 and 5 of E.O. 13846);
iii. Sanctions on transactions by FFIs with the CBI and designated Iranian financial institutions under section 1245 of the National Defense Authorization Act for FY 2012 (NDAA 2012) (see, e.g., section 5 of E.O. 13846, section 1245 of NDAA 2012, and subsection 1247(a) of IFCA);
iv. Sanctions on the provision of specialized financial messaging services to the CBI and Iranian financial institutions described in subsection 104(c)(2)(E)(ii) of CISADA (see, e.g., section 5 of E.O. 13846, section 220 of TRA, and subsection 1244(c)(1) of IFCA);
v. Sanctions on the provision of underwriting services, insurance, or reinsurance (see, e.g., section 5 of E.O. 13846, section 5(a)(7) of ISA, subsections 211(a) and 212(a) of TRA, and subsections 1246(a) and 1247(a) of IFCA); and
vi. Sanctions on Iran’s energy sector (see, e.g., subsection 1(a)(iv) and section 5 of E.O. 13846, subsection 5(a) of ISA, section 212(a) of TRA, and sections 1244(c)(1), (d) and (h)(2), 1246(a), and 1247(a) of IFCA).