What U.S. Companies Need To Know About the Withdrawal from the Iran Nuclear Deal and Renewed Sanctions

President Trump announced on May 8, 2018 that the United States is withdrawing from the Iran nuclear deal, known as the Joint Comprehensive Plan of Action (JCPOA). As a result of the withdrawal, the U.S. government will re-impose all U.S. sanctions against Iran that had been suspended as part of the JCPOA.

Pursuant to the JCPOA, which was signed under President Obama in 2015, Iran agreed to limit its nuclear program by curbing its enrichment of uranium, spent fuel processing, and research and development activities. In exchange, the U.S. lifted most “secondary sanctions” targeting non-U.S. persons and companies that transact business with Iran and allowed the importation of certain Iranian products into the U.S. In addition, the U.S. allowed non-U.S. entities that are owned or controlled by U.S. persons to engage in certain transactions with Iran under OFAC’s General License H. A number of foreign affiliates of U.S. companies started doing business and made investments in Iran pursuant to these authorizations.

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