Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran.

As reported in the Latham Client Alert dated May 10, 2018, President Trump announced on May 8 that the United States was withdrawing from the Joint Comprehensive Plan of Action (JCPOA), the January 2016 nuclear non-proliferation agreement among China, France, Germany, Russia, the United Kingdom, the US and Iran. The US withdrawal triggered the re-imposition of Obama-era US sanctions that had been suspended under the terms of the JCPOA. After a staged approach ending on November 4, 2018, the full arsenal of US primary and secondary sanctions against Iran is now in place. As Latham reported previously, these sanctions have the potential to reach any person or entity in the world that engages in transactions or dealings with Iran.