Introduction
On May 8, 2018 President Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) and would re-impose the U.S. secondary sanctions against Iran which had been suspended upon the commencement of the JCPOA. On August 6, 2018 President Trump issued Executive Order 13846 which re-imposes the secondary sanctions. However, for certain categories of transactions, including those relating to Iranian petroleum and petroleum products, a previously established wind-down period remains in effect until November 4, 2018. To view Executive Order 13846, click here. To view FAQs issued by the Office of Foreign Asset Control (“OFAC”) regarding the Executive Order, click here.
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