Snapback to Uncertainty? U.S. Announces New Designations, Reversion to Secondary Sanctions

Last August, citing Iranian “provocations,” including increased uranium enrichment and joint missile technology exchanges with North Korea, Pompeo announced the U.S. intention to invoke the so-called “snapback” provisions of the 2015 Joint Comprehensive Plan of Action (JCPOA). This not only reactivated alleged secondary sanctions (applicable to nations, persons and entities not directly subject to U.S. jurisdiction), but also proposed a resolution to reimpose the UN embargo on arms sales and shipments to Iran (scheduled to expire October 18, 2020).

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