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August 20, 2018

Executive Order is Issued to Reimpose Certain Iran Sanctions

By: Lindsey Roskopf

On August 6, 2018, the President signed Executive Order 13846, which reimposes certain sanctions with respect to Iran that were lifted or waived in connection with the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA).  Specifically, sanctions on the following activities were reimposed:

In addition, the Executive Order broadened the scope of certain sanctions that were in effect prior to the JCPOA implementation by providing new authority to sanction persons on or after November 5, 2018 who are determined to provide material support for, or goods and services in support of, persons blocked for:

The Executive Order also expands the menu of sanctions available for persons determined to have, on or after November 5, 2018, knowingly engaged in certain significant transactions relating to petroleum, petroleum products, or petrochemicals from Iran. 

As a reminder from our article last month, following a 180-day wind down period ending on November 4, 2018, the U.S. government will reimpose the following sanctions that were lifted pursuant to the JCPOA:

In addition, effective November 5, 2018, the U.S. government will revoke the authorization for U.S.-owned or -controlled foreign entities to wind down certain activities with the Government of Iran or persons subject to the jurisdiction of the Government of Iran that were previously authorized pursuant to General License H.