U.S. Reimposes Final Tranche Of Iran-Related Sanctions

On November 5, 2018, the United States took steps to complete the U.S. withdrawal from the Joint Comprehensive Plan of Action ("JCPOA"), under which the United States - along with its partners in the P5+11 - had previously agreed to suspend or waive certain sanctions on Iran in exchange for limitations on Iran's nuclear program. It did so by reimposing the final tranche of sanctions against Iran pursuant to Executive Order ("E.O.") 13846 and imposing blocking sanctions on hundreds of additional targets.

These sanctions include the following:

Blocking Sanctions

On Iran's designated port operators, and designated persons in Iran's shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines ("IRISL"), South Shipping Line Iran, or their affiliates2; On designated persons that are part of Iran's energy sector; On transactions that materially assist the National Iranian Oil Company ("NIOC"), the Naftiran Intertrade Company ("NICO"), and the Central Bank of Iran ("CBI"); On persons determined to have: (a) been involved in various corruption-related activities; (b) transferred or facilitated the transfer to Iran of goods or technologies that the Iranian government would likely use to commit serious human rights abuses against its people; or (c) engaged in censorship or related activities with respect to Iran after 2009. Correspondent and Payable-Through Account Sanctions

On foreign financial institutions that engage in significant transactions with the CBI and designated Iranian financial institutions3; On foreign financial institutions that facilitate significant transactions with NIOC or NICO (subject to certain exceptions), or for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products or petrochemical products from Iran; On entities that provide underwriting services, insurance, or reinsurance, including with respect to Iran's energy, shipping, and shipbuilding sectors, as well as the broad range of Iran-related activities that are subject to U.S. sanctions. Menu-Based Sanctions4

On persons that engage in transactions for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products or petrochemical products from Iran. Our previous client alert includes further details on these sanctions.

OFAC revised the Iranian Transactions and Sanctions regulations to implement these sanctions and published several Frequently Asked Questions ("FAQs") to provide guidance on its interpretation of several implementation issues.5

Blocking Sanctions

OFAC added more than 700 individuals and entities to the list of Specially Designated Nationals and Blocked Persons ("SDN List"), covering "hundreds of targets previously granted sanctions relief under the JCPOA, as well as more than 300 new designations."6 These include many Iranian banks, their foreign and domestic subsidiaries, Iranian vessels, energy firms, and the Iranian airline Iran Air.

Under the JCPOA, the U.S. had suspended secondary sanctions for certain dealings involving parties on the List of...