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Iran has meant that the defects began to matter much more. The appointment of two key Iran sceptics, John Bolton (National Security Advisor) and Mike Pompeo (Secretary of State) effectively sealed the fate of the Iran deal, providing President Trump with a core of foreign policy advisors who shared his dim view of Iran deal and wanted it “nixed”. The initial fear was that President Trump would refuse to renew the next set of waivers that were due to expire. The complex manner in which the US sanctions were imposed - piecemeal through a number of Congressional acts and Executive Orders - and in which the waivers were put in place meant that different sets of sanctions expired at different times. The waiver of the secondary sanctions providing for penalties against foreign financial institutions that engage in significant financial transactions with Iran’s central bank were due to expire on 12th May. Other secondary sanctions targeting broader economic activities were due to expire in July 2018. “The appointment of two key Iran sceptics, John Bolton (National Security Advisor) and Mike Pompeo (Secretary of State) effectively sealed the fate of the Iran deal, providing President Trump with a core of foreign policy advisors who shared his dim view of Iran deal and wanted it “nixed”. ” However, President Trump chose to announce the reintroduction of the whole gamut of US secondary sanctions, and withdraw various general licences issued pursuant to the JCPOA, without waiting for the waivers to expire. When “wind down” periods of 90 and 180 days (dependent on the types of sanctions concerned) are taken into account, this means that US secondary sanctions will effectively come back into effect on 6th August 2018 and 4th November 2018. In particular, after 6th August 2018, the US will re-impose sanctions on: – the purchase or acquisition of U.S. dollar banknotes by the Government of Iran; – Iran’s trade in gold or precious metals; – the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as aluminium and steel, coal, and software for integrating industrial processes;
“...President Trump chose to announce the reintroduction of the whole gamut of US secondary sanctions, and withdraw various general licences issued pursuant to the JCPOA, without waiting for the waivers to expire.” – significant transactions related to the purchase or sale of Iranian rials, or the maintenance of significant funds or accounts outside the territory of Iran denominated in the Iranian rial; – the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and – Iran’s automotive sector. Moreover, after 4th November, the US will re-impose sanctions on: – Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping Line Iran, or their affiliates; – - petroleum-related transactions with, among others, the National Iranian Oil Company (NIOC), Naftiran Intertrade Company (NICO), and National Iranian Tanker Company (NITC), including the purchase of petroleum, petroleum products, or petrochemical products from Iran; – transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions; – the provision of specialized financial messaging services to the Central Bank of Iran and Iranian financial institutions; – the provision of underwriting services, insurance, or reinsurance; and – Iran’s energy sector. General licences allowing foreign subsidiaries of US companies to engage in transactions with Iran in specified circumstances are also being withdrawn and Iranian financial institutions and government of Iran entities will be added to the SDN list, with secondary sanctions consequences for non-US persons who deal with them. The President’s announcement is of nothing less than a wholesale reintroduction of the pre-implementation day US secondary sanctions regime.
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