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U.S. Reimposes all Sanctions on November 5, 2018 Lifted under Former Iran Nuclear Deal

U.S. Reimposes all Sanctions on November 5, 2018 Lifted under Former Iran Nuclear Deal

November 4, 2018 was the last day of the 180-day wind-down period following President Trump’s May 8, 2018 announcement to withdraw the US’ participation from the Joint Comprehensive Plan of Action (the Nuclear Deal).  On November 5, 2018, the US fully reimposed the sanctions on Iran that had been lifted under the Nuclear Deal.  These tough sanctions on Iran target critical sectors of Iran’s economy, including the energy, shipping and shipbuilding, as well as financial sectors.
As part of the re-imposition of U.S. sanctions against the Iranian regime, OFAC sanctioned more than 700 individuals, entities, aircraft, and vessels on November 5, 2018.
Additionally, on November 5, 2018, OFAC moved persons identified as meeting the definition of the terms “Government of Iran” or an “Iranian financial institution” from the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) to the SDN List and removed the E.O. 13599 List from its website.   This, in effect, moved these persons back into “blacklisted” status.
Notably, the Wall Street Journal reported November 7, 2018 at
  “For some Western companies whose dealings with Iran are primarily limited to export, the trade had already subsided so much as a result of Iran’s economic woes that the new U.S. restrictions are unlikely to have a major impact.
The Iranian rial’s sharp loss in value caused California-based Del Monte to stop exporting packaged food to Iran several months ago because its products were suddenly much more expensive.
‘They are very cautious to not buy food from outside,’ Muhammad Adil Imtiaz, a Dubai-based sales manager for Del Monte, said of Iranian buyers. ‘For consumers buying any product, not just food but garments and electronics, the prices have changed completely on the shelves.'”
The impact of the re-imposed sanctions were already having the intended impact prior to November 5, 2018.  For example as reported in the same above article, the Europeans are resorting to creating an alternative financing vehicle to operate outside the U.S. financial system in effort to permit EU countries to continue to adhere to the Iran Nuclear Deal, an effort that has met with many snags.