OFAC amended the Iranian Transactions and Sanctions Regulations (“ITSR”) to implement the President’s May 8th, 2018 decision to withdraw from the JCPOA, as outlined in the National Security Presidential Memorandum (“NSPM”): Anyone engaging in any activities which are contrary to the current sanctions laws could be liable for such activities. Wind-down of Iran-related activities pursuant to authorizations provided by the JCPOA is required in the next 90 or 180 days depending on the nature of the transaction.
Wind-down of JCPOA Related Activity and the Re-imposition of SanctionsĪll of the sanctions in existence prior to the JCPOA including nuclear-related secondary sanctions will be in effect on November 5, 2018.
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