May 9, 2019
Introduction
On May 8, 2019, exactly one year after 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, President Trump issued an Executive Order “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran.” The Executive Order is not yet numbered but is characterized as “further steps” taken under Executive Order 12957 of March 15, 1995.
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