On August 7, 2018, the U.S. reinstated the first wave of sanctions against Iran as the 90-day wind-down period concluded. The Trump administration reimposed sanctions that prohibit Iran purchasing U.S. banknotes, commercial aircraft, trading gold and metals, and business with Iran’s automotive sector.
The snapback provisions were evoked by President Trump’s May 8, 2018 decision to withdraw from the 2015 Joint Comprehensive Plan of Action (“JCPOA”). Under direction from the Administration, federal agencies implemented 90-day and 180-day wind-down periods for activities involving Iran that were consistent with the sanctions relief detailed in the JCPOA.
In addition to the reinstatement of select pre-nuclear deal secondary sanctions, the Administration terminated JCPOA-related authorizations that permitted the importation of Iranian-origin carpets and foodstuffs; the exportation of civilian aircraft to Iran; and activities undertaken pursuant to General License I.