Episode 55 -- Update on the Iran Sanctions Program

On May 8th, 2018, the Trump administration withdrew from the Joint Comprehensive Plan of Action or JCPOA and began to reimpose the U.S. nuclear-related sanctions. All of the sanctions in existence prior to the JCPOA including nuclear-related secondary sanctions will be effective on November 5, 2018.  The wind-down of Iran-related activities pursuant to authorizations provided by the JCPOA is required in two wind-down periods – a 90 day period which just ended, and a second 180-day period, which occurs on November 5, 2018.

On August 6, 2018, the Trump administration issued a new executive in order to reimpose the first tranche of the Iran sanctions. In doing so, the executive order consolidates relevant sanctions authorities and broadens the scope of the previous restrictions.

The re-imposed sanctions create significant compliance obligations, and in particular, in the third-party risk management area.

In this episode, Michael Volkov reviews the re-imposed sanctions, the broader authorities and new third-party risks created by the new regulations.