An Uncertain Future: The US Pulls Out Of the Iran Deal
By Zia Ullah, Mark D. Herlach, James Lindop and Victoria Turner
Reprinted with permission from Eversheds Sutherland.
President Trump announced last week that the US will withdraw from the Iran nuclear deal and will begin re-imposing those sanctions which were lifted as part of the Joint Comprehensive Plan of Action (“JCPOA”). In a move which former President Obama has described as “misguided” and a “serious mistake”, President Trump signed a National Security Presidential Memorandum directing relevant US agencies (including the Treasury) to take actions necessary to start re-imposing sanctions, meaning that secondary sanctions, which impact on non-US persons, will come back into effect. President Trump’s announcement also leaves open the possibility for new and additional sanctions to be imposed in the future.
Last week’s announcement confirmed that there will be wind-down periods before sanctions are fully re-imposed.