Iran Sanctions Affecting Foreign Subsidiaries, Financial Transactions Reinstated
As expected, President Trump took action on Aug. 6 to begin reimposing nuclear-related primary and secondary sanctions against Iran following a decision to cease the United States’ participation in the Joint Comprehensive Plan of Action. Under the JCPOA, the U.S. and the European Union lifted economic and financial nuclear-related sanctions on Iran in January 2016 in exchange for Iran’s significant curtailment of its nuclear program.
Sanctions reimposed effective Aug. 7 include sanctions on the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial processes, as well as sanctions on the sale, supply, or transfer to Iran of significant goods or services used in connection with Iran’s automotive sector. Also, the U.S. has revoked JCPOA-related authorizations for imports of Iranian-origin carpets and foodstuffs and certain related financial transactions as well as activities undertaken pursuant to specific licenses allowing exports of commercial passenger aircraft and related parts and services to Iran for exclusively civil aviation end-use (which have also been revoked).
Sanctions to be reimposed on Nov. 5 include sanctions on Iran’s port operators and shipping and shipbuilding sectors, sanctions on petroleum-related transactions with certain entities, and sanctions on the provision of underwriting services, insurance, or reinsurance. In addition, effective Nov. 5 the U.S. will revoke the authorization for U.S.-owned or -controlled foreign entities to wind down certain activities with the government of Iran or persons subject to the jurisdiction of the government of Iran that were previously authorized pursuant to General License H. Finally, no later than Nov. 5 the U.S. will reimpose the sanctions that applied to persons removed from the List of Specially Designated Nationals and Blocked Persons and/or other lists maintained by the U.S. government on Jan. 16, 2016.