On August 6, 2018, President Trump issued Executive Order 13846, “Reimposing Certain Sanctions with Respect to Iran” (the “New Iran EO”), which formally reimposes certain sanctions on Iran that had been suspended or revoked as part of the United States’ commitments under the Joint Comprehensive Plan of Action (“JCPOA”). The New Iran EO, which was issued to coincide with the end of the 90-day wind-down period announced on May 8, 2018 and detailed in our previous blog post, reimposes a wide range of sanctions on Iran that were in effect prior to the implementation of the JCPOA pursuant to pre-existing legal authorities, and also expands the scope of those sanctions, as described below.
On July 2, 2018 the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a temporary authorization permitting certain limited transactions with Zhongxing Telecommunications Equipment Corporation (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. (“ZTE Kangxun” and, collectively with ZTE Corporation, “ZTE”) that would otherwise be prohibited under the denial order BIS activated against ZTE on April 15, 2018. The license grants authorization to all persons, aside from those located in Cuba, Iran, North Korea, Sudan and Syria, to resume certain technical support activities with ZTE from July 2 to August 1, 2018.
Executive Summary Effective May 8, 2018, the US Government withdrew from the Joint Comprehensive Plan of Action (“JCPOA”). The US Government will re-instate the sanctions that were lifted or waived following the implementation of the JCPOA. This action has a greater impact on non-US persons because most of the lifted or waived sanctions were secondary sanctions targeting activities of non-US companies occurring outside of US jurisdiction. The sanctions will be re-instated on August 7,…
On May 8, 2018, President Trump announced that the United States will be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”), culminating months of uncertainty around the fate of the Iran nuclear deal. The announcement came ahead of a May 12 deadline for the renewal of a key sanctions waiver. As described here, the last sanctions waiver occurred on January 12, 2018 amidst statements by President Trump that the waiver would be the last unless what President Trump considered “flaws” in the deal were fixed. In his May 8 speech, President Trump announced that the United States would re-impose nuclear sanctions against Iran.