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US (Re-)Imposes Far-Reaching Sanctions With Respect to Iran

Author
Rivlin Ken
Ken Rivlin

Partner

New York

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Maura Rezendes

Partner

Washington, D.C.

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Chiang Kuang
Kuang Chiang

Associate

Washington, D.C.

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Ognibene Nick
Nick Ognibene

Associate

New York

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French Tracy
Tracy French

Associate

Washington, D.C.

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16 August 2018

Following the administration’s withdrawal of the United States from the Joint Comprehensive Plan of Action (JCPOA) in May 2018 and the expiry of the first of two accompanying wind-down periods on August 6, 2018, President Trump issued Executive Order 13846 Reimposing Certain Sanctions With Respect to Iran (EO 13846), which authorizes and imposes a range of sanctions targeting persons engaged in various transactions involving Iran.  OFAC concurrently released new FAQs regarding the EO 13846 and the newly-imposed sanctions.  EO 13846 not only re-imposes certain of the sanctions with respect to Iran that had previously been suspended pursuant to the JCPOA, but also broadens the scope of the pre-JCPOA sanctions.    

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