Iran Sanctions Update: August Implementation Deadline Is Approaching, Are You Ready?

President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA) on 8 May 2018. In conjunction with that announcement, the president issued a National Security Presidential Memorandum 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. Depending on the economic sector targeted, the particular sanction will be imposed either 90 or 180 days after the president's announcement (and so, on 6 August or 5 November 2018).

Implementation of the first batch of sanctions is rapidly approaching. On 6 August, the United States will re-impose the following secondary sanctions that were lifted as part of the JCPOA: