- Previously permissible activities must be wound down in 90 or 180 days
- Non-U.S. companies at particular risk of enforcement action
- Only limited guidance issued so far, unclear what authority U.S. companies have
On May 8, 2018, President Trump announced that the United States is leaving the Joint Comprehensive Plan of Action (JCPOA). The U.S. Treasury, Office of Foreign Assets Control (OFAC), which administers most U.S. economic sanctions programs, has taken an initial stab at providing guidance in a set of Frequently Asked Questions (FAQs) released the same day as the President’s announcement.