Iran Sanctions


On May 8, 2018, President Trump announced his decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) and to begin re-imposing the U.S. nuclear-related sanctions on Iran that were lifted to effectuate the JCPOA sanctions relief, following 90-day and 180-day wind-down periods. It is important to remember that Iran advanced its march across the Middle East during the JCPOA. As Secretary of State Mike Pompeo noted back in May, “the Iranian government used the sanctions relief from the JCPOA to spend its newfound treasure fueling proxy wars across the Middle East and lining the pockets of the Islamic Revolutionary Guard Corps, Hizballah, Hamas, and the Houthis.”

The JCPOA did nothing to control ballistic missile development, enriched Iranian proxy forces including named terrorist groups, and empowered and emboldened the worst excesses of the Iranian regime. President Trump’s new Iran Strategy is a tremendous shift in the right direction, away from the delusion that the Iranian regime is a partner for peace toward the reality that it is a malign influence and actor. Leveraging economic sanctions is crucial to the President’s overall strategy against Iran. It is vital to note though that the ultimate target is not the Iranian people, but the regime itself.

As yesterday marked the final day of the 90-day wind-down period before the sanctions go into effect, the President issued an Executive Order to reimpose relevant provisions of five Iran sanctions E.O.s that were revoked or amended by E.O. 13716 on January 16, 2016.

The provisions included reimposing sanctions on Iran’s automotive sector and on its trade in gold and precious metals, as well as sanctions related to the Iranian rial, steel, coal and more.

All remaining United States nuclear-related sanctions will resume effective November 5, 2018. These include sanctions targeting Iran’s energy sector, including petroleum-related transactions, as well as transactions by foreign financial institutions with the Central Bank of Iran. The Administration will also relist hundreds of individuals, entities, vessels, and aircraft that were previously included on sanctions lists. The Trump Administration intends to fully enforce the sanctions reimposed against Iran, and those who fail to wind down activities with Iran are risking severe consequences.

These sanctions will remain in effect unless Tehran meets a dozen stringent demands, including that it cease its support for militant groups in the Middle East and end its enrichment of uranium, but as President Trump has made clear, anyone doing business with Iran will not be doing business with the United States. Here’s looking at you at Europe.