November 9, 2018
A Road Map of the Re-Imposed Sanctions for Iran
By David Mortlock and Nikki M. Cronin
On November 5, 2018, the United States completed the re-imposition of nuclear related secondary sanctions on Iran. US President Donald Trump had announced in May that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”) with Iran. To re-impose the sanctions, the US Departments of State and Treasury have revoked licenses that authorized certain activity with Iran as well as the waivers that were issued to lift the threat of secondary sanctions against non-US persons engaged in certain transactions involving particular Iranian individuals or entities. In “A Road-Map of the Re-Imposed Sanctions for Iran” authors David Mortlock, a senior fellow with the Atlantic Council’s Global Energy Center, and Nikki M. Cronin, an Associate at Willkie Farr & Gallagher LLP, provide a detailed, technical overview of the secondary sanctions on Iran that took effect on November 5, 2018.
Read the Publication (PDF)