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Trump Withdraws US From JCPOA, Setting Stage for Return of Iran Sanctions

President Donald Trump on May 8 withdrew U.S. participation in the Joint Comprehensive Plan of Action, setting the stage for sanctions suspended under the agreement to once again take effect. In a presidential memorandum announcing the decision, Trump directed the State and Treasury departments to “immediately begin taking steps to re-impose” all U.S. sanctions “waived in connection with the JCPOA,” and do so “as expeditiously as possible.” The memo set a deadline of November 2018 for putting the sanctions back in place.

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According to the memo, sanctions removed as a result of the JCPOA and now set for re-imposition include “those under the National Defense Authorization Act for Fiscal Year 2012, the Iran Sanctions Act of 1996, the Iran Threat Reduction and Syria Human Rights Act of 2012, and the Iran Freedom and Counter-proliferation Act of 2012.” The move will also result in the relisting of persons removed from denied persons lists as a result of JCPOA. State and Treasury may issue “limited waivers during the wind-down period, as appropriate,” the memo said.

Treasury and State will establish a “90-day and a 180-day wind-down period for activities involving Iran that were consistent with the U.S. sanctions relief provided for under the JCPOA,” the Office of Foreign Assets Control said in a frequently asked questions document. As of Aug. 6, sanctions will return on trade in previous metals, raw materials like aluminum and steel, carpets and foodstuffs and certain financial activities. Remaining sanctions on Iranian shipping, petroleum and financial institutions will be put back in place on Nov. 5, OFAC said.