On May 8, 2018, President Trump announced that the United States is leaving the Joint Comprehensive Plan of Action (JCPOA). The U.S. Treasury, Office of Foreign Assets Control (OFAC), which administers most U.S. economic sanctions programs, has taken an initial stab at providing guidance in a set of Frequently Asked Questions (FAQs) released the same day as the President’s announcement.

While there were signs the President could leave the JCPOA (see our December 2016 blog posting), the President’s announcement means that the United States will indeed be re-imposing the nuclear-related sanctions that were lifted under the JCPOA. Some of the sanctions will be re-imposed within 90 days; all of the sanctions will be re-imposed within 180 days.

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