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ARTICLE · 10 FEBRUARY 2025

"Maximum Pressure" On Iran Is Back: What This Means For Sanctions And Export Controls

Crowell & Moring LLP
Crowell & Moring LLP
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Crowell & Moring LLP

Crowell & Moring LLP

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On February 4, 2025, President Trump issued a National Security Presidential Memorandum (NSPM-2) on "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence."

United StatesInternational Law
David (Dj) Wolff
David (Dj) Wolff
Carlton Greene
Carlton Greene
Erik Woodhouse
Erik Woodhouse
Maria Alejandra del-Cerro
Maria Alejandra del-Cerro
Anand Sithian
Anand Sithian
Jeremy Iloulian
Jeremy Iloulian

What You Need to Know

  • Key takeaway #1
     As expected, President Trump has directed relevant agencies to use sanctions and export controls to increase pressure on Iran, which could include extensive ongoing designations of entities and individuals, especially those involved in Iran's oil exports or other revenue-generating activities, narrowing or withdrawal of existing waivers and general licenses, and an aggressive approach to civil and criminal enforcement.
  • Key takeaway #2
     The U.S. Department of the Treasury has been instructed to consider new "Know-Your-Customer's-Customer" requirements for transactions involving Iran; if implemented, this could substantially increase risk and compliance requirements for financial institutions, even when seemingly engaged in non-Iran related activity.

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