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On May 8, 2018, President Trump exercised his authority to reimpose the secondary Iran sanctions that had been waived under the 2015 Joint Comprehensive Plan of Action (“JCPOA,” or the so-called “Iran Deal”). A number of intermediate courses of action were available, but the President opted for the most direct and complete. In signing (before the cameras) the National Security Presidential Memorandum, he directed that at the close of “wind-down” license periods of 90 or 180 days (depending on the sanctions involved), all prior statutory and Executive Orderimposed secondary sanctions be reimposed, all General Licenses (except those categorized as pre-JCPOA “humanitarian”) rescinded, and persons removed under JCPOA from the list of Specially Designated Nationals (“SDNs” or “Executive Order 13599 list”) maintained by the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) eventually re-listed.

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