On May 8, 2018, President Donald Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) negotiated between the “P5+1” countries (United States, United Kingdom, France, Germany, China, and Russia) and Iran. Under the JCPOA, which went into effect in January 2016, Iran agreed to strict curbs on its nuclear program in exchange for the United States, Europe, and the United Nations suspending or revoking a number of sanctions.

President Trump issued a National Security Presidential Memorandum ("NSPM”) on “Ceasing US Participation in the JCPOA and Taking Additional Action to CounterIran’s Malign Influence and Deny Iran All Paths to a Nuclear Weapon,” which orders the State Department and Treasury Department to “immediately begin taking steps to re-impose all United States sanctions lifted or waived in connection with the JCPOA[.]” The White House also issued a fact sheet on Ending United States Participation in an Unacceptable Iran Deal, and the Treasury Department’s Office of Foreign Assets Control (“OFAC”) also issued wind-down Frequently Asked Questions (“FAQs”).