The U.S. withdrawal from the JCPOA  and snapback led to Washington’s reimposition of highly onerous sanctions against Iran, its agents, and nearly all of its state-owned businesses. This means U.S. persons and companies are largely prohibited from doing business in or with Iran. In addition, the U.S. has reimplemented “secondary sanctions,” which affect entities outside the jurisdiction of the United States. The penalties imposed for violating U.S. sanctions are significant, including asset freezes, prohibitions on transactions with the U.S. financial system, and bans on the importation of U.S.-origin goods.  Civil or criminal penalties may also be assessed under the U.S. Anti-Terrorism Act and the Iranian Transactions and Sanctions Regulations, which authorize sanctions on any persons, including U.S.-based companies, who provide financial, material, or technological support to or on behalf of foreign persons designated for involvement in acts of terrorism that threaten US national security.

Since the U.S. withdrawal from the JCPOA and especially from late 2022, U.S. partners and allies, including the United Kingdom, the European Union, Canada, Australia, and New Zealand, have all imposed several new rounds of sanctions in response to Iran’s brutal suppression of its own people and support to Russian President Putin in his invasion of Ukraine.

Companies should be aware of the risk of partisan paralysis in Washington, D.C., and future sanctions packages. As long as Washington does not secure a verifiable agreement with the Islamic Republic acceptable by reasonable swaths of Democrats and Republicans, this policy paralysis and risk of sanctions reimposition will continue.  

The United Nations also retains broad sanctions relating to Iran’s sponsorship of international terrorism and human rights violations remain in effect and are unaffected by Iran’s stated decision to curtail its nuclear activities.