End of first wind-down period

Following President Trump’s decision on 8 May 2018 to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), the US government announced that it would re-impose pre-JCPOA nuclear related sanctions (both primary and secondary) that were lifted under the JCPOA. As we reported previously, two ‘wind-down’ periods – of 90 and 180 days respectively – commenced from the day of the announcement, during which non-US, non-Iranian companies were encouraged by the US government to withdraw from operations in Iran that would be affected by re-imposed sanctions.

On 6 August 2018 the first of these wind-down periods expired. President Trump issued a new Executive Order (“New EO”) re-imposing sanctions effective as of 7 August 2018. For our full briefing on the matter, please click here.

 

Daniel Hudson
Daniel Hudson
Partner
+44 20 7466 2470
Susannah Cogman
Susannah Cogman
Partner
+44 20 7466 2580
Jonathan Cross
Jonathan Cross
Counsel
+1 917 542 7824
Geng Li
Geng Li
Associate
+1 917 542 7828

Elizabeth Cahill
Elizabeth Cahill
Associate
+44 20 7466 2487