On 8 May 2018, President Trump announced that the United States
would withdraw from the Joint Comprehensive Plan of Action (JCPOA).
In conjunction with that announcement, the President issued a
National Security Presidential Memorandum (NSPM) directing the
re-imposition of certain secondary sanctions, being those that
apply to non-U.S. persons even where there is no U.S. nexus
(e.g. no U.S. persons, no U.S.-origin goods, or U.S.
dollar payments). As discussed in our earlier
blog post, the first batch of sanctions was reimposed on 6
August and the second batch will become effective 5 November.
On 5 November, the United States will re-impose the following
secondary sanctions:
- Sanctions on Iran's port
operators and shipping and shipbuilding sectors, including
IRISL;
