Pub. 8 2018-2019 Issue 4

12 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S FEATURE ARTICLE BY AMBER GOODRICH Joined by Iran, China, France, Germany, Russia, the United Kingdom and the United States, the JCPOA allowed sanctions relief to Iran in exchange for curbing its nuclear-related programs. Re-Instated Iran Sanctions What Do They Mean for Your Bank? O n May 8, 2018, President Trump an- nounced his decision to withdraw the United States from the Iran Deal, also known as the Joint Comprehensive Plan of Ac- tion (JCPOA), a treaty implemented on Jan. 16, 2016. Joined by Iran, China, France, Germany, Russia, the United Kingdom and the United States, the JCPOA allowed sanctions relief to Iran in exchange for curbing its nuclear-related programs. In conjunction with Trump’s decision, the U.S. reinstated nuclear sanctions on Iran at the conclusion of two wind-down periods, the second of which ended Nov. 4. The wind-down allowed U.S. organizations time to wrap up all soon-to-be sanctioned transactions with Iran. According to the Treasury Department, “Persons engaging in activity undertaken pur- suant to the U.S. sanctions relief provided for in the JCPOA should take the steps necessary to wind down those activities … to avoid ex - posure to sanctions or an enforcement action under U.S. law.” The re-instated sanctions cover various types of transactions with Iran in the energy, shipping and banking sectors, including the purchase or acquisition of U.S. dollar banknotes by the Government of Iran; sanctions on pe- troleum-related transactions, including the purchase of petroleum, petroleum products or petrochemical products from Iran; the provision of underwriting services, insurance or rein- surance; and transactions by foreign financial institutions with the Central Bank of Iran and other designated Iranian financial institutions. According to an Op-Ed in the Financial Times by U.S. Treasury Secretary Steven Mnuchin, “These actions are an important step towards holding the world’s largest state sponsor of terror accountable for its malign behavior, human rights abuses, ballistic missile development, and systematic efforts to exploit the global financial system to fund its revolu - tionary ambitions.” What Does This Actually Mean? Perhaps the biggest and most significant aspect of our country’s Iran Deal withdrawal is the re-instatement of a substantial subset of Iranian names and entities to OFAC’s Spe- cially Designated Nationals (SDN) list, those