On May 27, 2020, Secretary of State Michael Pompeo announced plans to end a sanctions waiver for all remaining nuclear projects in Iran that originated under the Joint Comprehensive Plan of Action (JCPOA). According to Pompeo, the sanctions waiver is ending because of Iran’s continued efforts to expand sensitive nuclear activities, in an effort to increase pressure on Iran and isolate the regime from the international community. Toward this end, Pompeo also announced the designation of two Iranian nationals, pursuant to Executive Order 13382, who have supported Iran’s weapons program by contributing to the production of uranium enrichment centrifuge operations in Iran.
In response to Pompeo’s announcement, the US Department of the Treasury’s Office of Foreign Assets Control updated its Frequently Asked Questions to emphasize a 60-day wind-down period to allow anyone engaged in projects permitted by the sanction waivers, to cease activities without exposure to covered sanctions. According to FAQ 829, the 60-day wind-down period officially ends on July 27, 2020, and anyone who knowingly engages in transactions with covered entities after this date, may be exposed to certain sanctions under the Iran Freedom and Counter-Proliferation Act (IFCA) if they fail to obtain a waiver or exception.
Department of State Press Statement | Department of Treasury Press Release | OFAC FAQ 829