Due to the United States’ withdrawal from the Joint Comprehensive Plan of Action, also known as the Iran deal, and the lack of commitments by the European Union to adequately secure their obligations under the JCPOA, Iran decided to enrich uranium past the established limitations. Iran was only permitted to enrich uranium at 3.67 percent, and the uranium stockpile was capped at 300 kilograms. With the recent announcement, Iran decided to enrich uranium at 4.5 percent.

Iran has slowly indicated that they are not going to comply with the JCPOA if Europe and the United States do not commit to their obligations. Particularly, they want the trade and economic benefits and the sanctions relief that Iran was promised.

Impact on US-Iran Relations and Sanctions Law

Iran’s decision to disregard the JCPOA further endangers the possibility of the sanctions relief provided by the United States to Iran due to the existence of the JCPOA. Though the United States did reimpose the sanctions, they have stated that they are willing to provide sanctions relief if Iran comes back to the negotiating table. Iran has stated that the United States must first abide by the agreement that was already in place prior to any negotiations on further restrictions to Iran’s nuclear program and any further sanctions relief.

It has been reported that French President Emmanuel Macron has been attempting to set the terms necessary for Iran to come back to the negotiating table with the United States. This may result in further negotiations between the US and Iran to restart the diplomatic pursuit of some form of international accord, which would, in turn, provide sanctions relief to Iran.

With further alterations to the sanctions regime on Iran, OFAC may have expanded authorities. OFAC may have the ability to both designate and put on the SDN list persons in the Iranian government, persons from Iran, or persons trading with Iran.

Speak to an OFAC Attorney About Your Transactions with Iran

US sanctions law is an ever-changing landscape, and it can be difficult to stay up to date. If you or your company does business with Iranian persons or entities, you should consult an OFAC attorney for help with sanctions compliance. They could review your transactions, advice you about a compliance program, or pursue any necessary licenses or waivers.