Iran sanctions: Snapback becomes reality

The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the Iran nuclear deal (see our prior alerts for more details about that announcement).

On 6 August the president issued a new Iran-related executive order (the New Iran EO), which re-imposes relevant provisions of four previous executive orders (EOs) and revokes two EOs, but the same restrictions set forth in those revoked EOs have been incorporated into the New Iran EO so there has been no easing of sanctions as a result of such revocation. In connection with the New Iran EO, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued new Frequently Asked Questions (FAQs), amended FAQs related to the Iran Freedom and Counter-Proliferation Act of 2012, and revised FAQs released on 8 May 2018 in connection with the United States' withdrawal from the Iran nuclear deal.

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