Timeline: Snapback of U.S. Sanctions Post-JCPOA

On May 8, 2018, President Trump announced that the U.S. would withdraw from the JCPOA and that the State and Treasury Departments would “immediately begin taking steps to re-impose all United States sanctions lifted or waived in connection with the JCPOA” (see below). Some of these sanctions were re-imposed on August 6, 2018 (90 days after the President’s announcement). The rest were re-imposed on November 4, 2018 (180 days after the President’s announcement).

Activities Sanctionable Effective August 6

  • Purchase or acquisition of U.S. dollar banknotes by the Government of Iran;
  • Trade with Iran in gold and other precious metals;
  • Direct or indirect sale, supply, or transfer to Iran of graphite, raw or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial processes;
  • Significant transactions re: purchase or sale of Iranian rials or the maintenance of significant funds or accounts outside Iranian territory denominated in the rial;
  • Sanctions on the purchase, subscription to, or facilitation of the issuance of Iran’s sovereign debt; and
  • Supply of goods and services used in connection with Iran’s automotive sector. 

Activities and Entities Sanctionable Effective November 4

  • Investment in the Iranian energy sector;
  • Purchase, acquisition, sale, transport, or marketing of Iranian petroleum, petrochemical products, and natural gas;
  • Transactions and dealings with the National Iranian Oil Company (NIOC), the National Iranian Tanker Company (NITC), and certain other designated individuals and entities that were removed from the Specially Designated Nationals (SDN) List on Implementation Day;
  • Transactions and dealings with the Central Bank of Iran (CBI) and other Iranian financial institutions; 
  • Providing financial-messaging services (such as SWIFT) to the CBI and Iranian financial institutions.
  • Provision of underwriting services, insurance, or reinsurance for activity consistent with the JCPOA; and
  • Iran’s port operators and shipping and shipping and shipbuilding sectors.