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ARTICLE · 12 JUNE 2018

Sanctions Against Iran Require Skill To Navigate

Duane Morris LLP
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In the press release accompanying President Donald Trump's May 8, 2018, decision to cease participation in the Joint Comprehensive Plan of Action (JCPOA) ...

United StatesInternational Law
Hersh Kozlov
Hersh Kozlov
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Intricate regulations will implicate transactions, banking and pharma, as well as supply chains across a range of global industries.

In the press release accompanying President Donald Trump's May 8, 2018, decision to cease participation in the Joint Comprehensive Plan of Action (JCPOA) and reinstate U.S. nuclear sanctions on the Iranian regime, President Trump hinted that additional sanctions would be forthcoming and that those would be the "highest level of economic sanctions." (See our previous Alert.) Two weeks later, U.S. Secretary of State Mike Pompeo appeared to confirm new sanctions when he threatened to impose "the strongest sanctions in history" on Iran.

While the administration contemplates new sanctions, previous sanctions that were suspended by operation of the JCPOA are now set to snapback. Included among these are secondary sanctions under the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA). Section 1244 of the IFCA, entitled "Imposition

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