On July 18, the State Department published a notice that Secretary Tillerson has certified that Iran remains in compliance with its obligations under the 2015 Joint Comprehensive Plan of Action (“JCPOA”), pursuant to which Iran agreed to restrictions on its nuclear program in return for sanctions relief (see our 2015 and 2016 memoranda). Recertification of compliance is required every 90 days under the Iran Nuclear Agreement Review Act of 2015. Despite President Trump’s criticism of the JCPOA, this is his Administration’s second certification of compliance.
As with the prior certification, the State Department’s announcement notes that the Administration is reviewing the suspension of sanctions pursuant to the JCPOA. The announcement also notes that the State Department and OFAC today designated an additional 18 Iranian entities and individuals for activities related to proliferation, ballistic missile development, support of the Iranian military and IRGC, and transnational criminal organizations; all of these sanctions authorities were unaffected by the JCPOA.
The next certification is due in mid-October.