November 4, 2018 marked the final day of the 180-day wind-down period following the President’s May 8, 2018 announcement to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA). On November 5, 2018, the United States fully re-imposed the sanctions on Iran that had been lifted or waived under the JCPOA. These are the toughest U.S. sanctions ever imposed on Iran, and will target critical sectors of Iran’s economy, such as the energy, shipping and shipbuilding, and financial sectors. The United States is engaged in a campaign of maximum financial pressure on the Iranian regime and intends to enforce aggressively these sanctions that have come back into effect.
On November 5, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) posted to its website additional frequently asked questions (FAQs) that provide guidance on the sanctions that have been re-imposed. In addition, OFAC amended FAQ 256 and FAQ 417, and archived outdated FAQs.
As part of the re-imposition of U.S. sanctions, in its largest ever single-day action targeting the Iranian regime, OFAC sanctioned more than 700 individuals, entities, aircraft, and vessels on November 5, 2018. This action was a critical part of the re-imposition of the remaining U.S. sanctions that were lifted or waived in connection with the JCPOA. For more information on this action, click here.
Additionally, on November 5, 2018, OFAC moved persons identified as meeting the definition of the terms “Government of Iran” or an “Iranian financial institution” from the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) to the SDN List and removed the E.O. 13599 List from its website.
Finally, OFAC also amended the Iranian Transactions Sanctions Regulations (ITSR), effective November 5, 2018 to, among other things, reflect the re-imposition of sanctions pursuant to certain sections of Executive Order 13846 and technical changes that remove references to the E.O. 13599 List.