Iran Sanctions: Snap-Back, Part 2

Executive Summary

On November 5, 2018, the United States enacted the second of two powerful phases of the "snap-back" of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of the Joint Comprehensive Plan of Action (JCPOA), commonly known as the Iran nuclear deal. As a result of the U.S. government's actions, non-U.S. individuals and entities – anywhere in the world – face the threat of powerful U.S. sanctions against them if they engage in trade or other transactions with Iran involving sanctioned parties or across a wide swath of key Iranian industry sectors, such as energy, financial, insurance, shipping, shipbuilding, port operations, automotive, gold and other precious metals, and mining.