On May 8, 2018 President Trump issued a National Security Presidential Memorandum, available here, announcing that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JPCOA”) and would re-impose the U.S. secondary sanctions against Iran which had been suspended upon the commencement of the JCPOA. Those secondary sanctions had restricted the activities of non-U.S. persons in relation to Iran. Two separate wind-down periods have been established, enabling non-U.S. persons to conclude Iranian transactions entered into prior to May 8. Also on May 8, the U.S. Office of Foreign Asset Control (“OFAC”) issued FAQs on the re-imposition of sanctions and the wind down periods, which can be reviewed here. At this point the re-imposition of U.S. sanctions against Iran is still being implemented and further developments are expected. To read the full Client Alert, click HERE.