In the midst of the ongoing Department of Justice investigation into the Trump campaign ties with Russian officials, on June 15, 2017, the US Senate voted 98-2 to pass a comprehensive Russia sanctions package. These measures were offered as an amendment to, and largely overshadowed, separate Iran sanctions legislation – the Countering Iran’s Destabilizing Activities Act of 2017 (S. 722).
On 17 May 2017, the US Department of State announced that the US Government would renew waivers of certain sanctions necessary to continue to implement US commitments under the Joint Comprehensive Plan of Action (“JCPOA”). On the same day, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated additional parties for their involvement in Iran’s military and ballistic missile program.
On April 18, 2017, the US Department of State notified the US Congress that Iran has been complying with the conditions of the Joint Comprehensive Plan of Action (“JCPOA”). The US Department of State is required to notify the US Congress every 90 days on Iran’s compliance with the JCPOA, and the April 18, 2017, notification was the first such notification under the Trump Administration.
On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending the licensing provisions of section 560.530 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (“ITSR”) and making certain other amendments to the ITSR (the “Final Rule”). Section 560.530 sets forth the favorable Ag/Med licensing regime for the export/reexport of agricultural commodities, medicine, and medical devices to Iran (i.e., “Ag/Med” licenses).