Pub.7 2018 Issue 4

The CommunityBanker 14 Re-Instated Iran Sanctions: What Do They Mean for Your Bank? By Amber Goodrich O n May 8, 2018, President Trump announced his deci- sion to withdraw the United States from the Iran Deal, also known as the Joint Comprehensive Plan of Action (JCPOA), a treaty implemented on Jan. 16, 2016. Joined by Iran, China, France, Germany, Russia, the United King- dom and the United States, the JCPOA allowed sanctions relief to Iran in exchange for curbing its nuclear-related programs. In conjunction with Trump’s decision, the U.S. rein - stated nuclear sanctions on Iran at the conclusion of two wind-down periods, the second of which ended Nov. 4. The wind-down allowed U.S. organizations time to wrap up all soon-to-be sanctioned transactions with Iran. According to the Treasury Department, “Persons engag- ing in activity undertaken pursuant to the U.S. sanctions relief provided for in the JCPOA should take the steps necessary to wind down those activities … to avoid exposure to sanctions or an enforcement action under U.S. law.” The re-instated sanctions cover various types of transactions with Iran in the energy, shipping and bank- ing sectors, including the purchase or acquisition of U.S. dollar banknotes by the Government of Iran; sanctions on petroleum-related transactions, including the purchase of petroleum, petroleum products or petrochemical products from Iran; the provision of underwriting services, insurance or reinsurance; and transactions by foreign financial institu - tions with the Central Bank of Iran and other designated Iranian financial institutions. According to an Op-Ed in the Financial Times by U.S. Treasury Secretary Steven Mnuchin, “These actions are an F E A T U R E