U.S. Government Fully Re-Imposes Iran Sanctions, Announces “Unprecedented” Sanctions Effort

On November 5, 2018, the United States completed the process of fully re-imposing sanctions related to Iran that were waived or lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) with Iran, consistent with President Trump’s May 8, 2018 announcement terminating the United States’ participation in the JCPOA.

While public statements from the administration emphasized the breadth of the sanctions and the government’s determination to fully enforce sanctions going forward as part of an “unprecedented” economic pressure campaign intended to deprive the Iranian government of revenue to engage in malign activities, the actions of the Treasury Department’s Office of Foreign Assets Control were largely consistent with prior guidance and served mostly to establish the appropriate framework for administration and enforcement of the re-imposed sanctions. Now that this restored framework is fully in place, it remains to be seen whether the U.S. government will be able to leverage these authorities to force changes in the Iranian regime’s behavior, and whether and to what extent it will follow through on threats to enforce secondary sanctions against non-Iranian actors in order to achieve this goal.