Reimposing Certain Sanctions With Respect to Iran

This executive order reimposes U.S. sanctions on Iran that had been lifted under the 2015 Iran nuclear deal (JCPOA), following President Trump's May 8, 2018 decision to withdraw from that agreement. It authorizes blocking sanctions, financial account restrictions, and menu-based penalties targeting Iran's energy, shipping, automotive, and financial sectors, as well as human rights abusers, with staggered effective dates starting August 7, 2018 and November 5, 2018.

Federal Register Open PDF 83 FR 38939

Impact dates

Nov 5, 2018
Expanded sanctions on petroleum/petrochemicals, NIOC/NICO, Central Bank of Iran take effect
Nov 4, 2018
Latest date by which all JCPOA-lifted sanctions to be reimposed (180 days from May 8, 2018 per NSPM-11)
Aug 7, 2018
EO effective; sanctions on bank notes/precious metals, automotive sector, and rial transactions take effect

Key directives

Reimpose all sanctions lifted/waived under JCPOA no later than 180 days from May 8, 2018 (by November 4, 2018)
Authorize blocking sanctions on persons supporting Iranian government purchase of U.S. bank notes/precious metals on or after August 7, 2018
Authorize blocking sanctions on persons supporting NIOC, NICO, or Central Bank of Iran on or after November 5, 2018
Authorize correspondent/payable-through account sanctions on foreign financial institutions for automotive sector transactions on or after August 7, 2018
Authorize correspondent/payable-through account sanctions for petroleum/petrochemical transactions on or after November 5, 2018
Authorize menu-based sanctions on persons engaging in significant automotive sector transactions on or after August 7, 2018
Authorize menu-based sanctions on persons engaging in petroleum/petrochemical trade on or after November 5, 2018
Impose sanctions on foreign financial institutions for rial transactions or rial-denominated accounts outside Iran on or after August 7, 2018
Block property of persons involved in diversion of humanitarian goods, human rights abuses technology, or censorship since specified past dates
Prohibit foreign subsidiaries of U.S. persons from transactions that would be prohibited if done by U.S. persons directly
Revoke and supersede Executive Orders 13628 and 13716
Suspend entry into U.S. of aliens meeting sanctions criteria

Who is ordered

Timeline

Immediate

EO effective 12:01 a.m. EDT August 7, 2018
Blocking sanctions authority active for bank notes/precious metals, automotive sector, and rial transactions
Foreign financial institution sanctions active for automotive sector and rial transactions

Near term (90d)

November 5, 2018: Expanded sanctions take effect for petroleum/petrochemical trade, NIOC/NICO, Central Bank of Iran, and broader SDN List support

Long term

Ongoing sanctions enforcement and potential designations
Structural impact on global Iran trade patterns
Potential future negotiations contingent on Iranian regime behavior

Risks & tensions

Diplomatic friction with JCPOA signatories (EU, UK, France, Germany, Russia, China) who opposed U.S. withdrawal
Potential humanitarian concerns despite explicit exemptions for agricultural commodities, food, medicine, medical devices
Risk of Iranian escalation in regional conflicts or nuclear program in response to renewed pressure
Economic impact on global oil markets from November 2018 petroleum sanctions
Uncertainty in implementation: multiple 'authorized to impose' provisions give discretion to Secretaries rather than mandating automatic sanctions
Extraterritorial reach may trigger EU blocking statute and other countermeasures