Effective Nov. 5 the Trump administration is reinstating the remaining nuclear-related primary and secondary sanctions against Iran that it lifted in January 2016 under the Joint Comprehensive Plan of Action in exchange for Iran’s significant curtailment of its nuclear program. The administration announced in August the U.S. withdrawal from the JCPOA.

Some sanctions were reimposed as of Aug. 7. These included 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. The U.S. also 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 were also revoked).

Sanctions being reimposed Nov. 5 include sanctions on Iran’s port operators and shipping and shipbuilding sectors, a prohibition on foreign country purchases of oil from Iran (though the U.S. has granted temporary waivers to eight “jurisdictions”), and sanctions on the provision of underwriting services, insurance, or reinsurance. In addition, the U.S. is revoking 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, the U.S. is reimposing 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.

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