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Developments in U.S. Iran Sanctions

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On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its illicit nuclear program. The President’s much-anticipated announcement does not mean that the United States is withdrawing from the JCPOA, nor does it automatically result in the re-imposition of any U.S. sanctions against Iran. Rather, the President’s announcement gives the U.S. Congress 60 days to introduce legislation to re-impose U.S. sanctions that could be considered under expedited procedures.

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