Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

President Trump Declines Certification of Iran Nuclear Deal: What Does This Mean?

By Cortney Morgan, Grant Leach & Katherine Stubblefield on October 13, 2017
Email this postTweet this postLike this postShare this post on LinkedIn

After undertaking a broader review of the United States’ policies with regard to Iran, President Donald Trump announced today that he will not certify the Iran nuclear deal, more commonly referred as the Joint Comprehensive Plan of Action (“JCPOA”). This move stops short of unraveling the deal but allows Congress to consider the agreement for the next 60 days on an expedited basis in order to decide whether to re-impose sanctions lifted under the terms of the agreement.

In refusing to certify Iran’s compliance, the President is not declaring that Iran has violated the terms of the JCPOA which imposed limits on its nuclear program in return for the lifting of certain sanctions. Rather, President Trump stated that Iran is “not living up to the spirit” of the agreement and invoked a provision in the Iran Nuclear Agreement Review Act (“INARA”), which asks whether the lifting of sanctions against Iran is in the national security interest of the United States and whether the action is “appropriate and proportionate” related to Iran’s efforts to restrict its nuclear program.

President Trump’s refusal to certify the criteria in INARA has no direct or immediate impact on the JCPOA. President Trump indicated a desire to “fix” some of the JCPOA provisions that he disagrees with. As a result, Congress may take action to impose sanctions which would put the US in breach of the JCPOA, or Congress may try to “fix” the problems, possibly by establishing “trigger points” which could induce the US to re-impose sanctions.

President Trump also announced a broad strategy toward Iran that will focus on “neutralizing the government of Iran’s destabilizing influence and constraining aggression, particularly its support for terrorism and militants.” As part of that strategy, the President authorized the Department of the Treasury to designate the Islamic Revolutionary Guard Corps (“IRGC”) as a terrorist organization and impose new sanctions again the IRGC. While the IRGC is already included on the Specially Designated Nationals (“SDN”) list and is blocked from most activity, today’s action will no longer allow the group to avail themselves of the Berman exception under the International Emergency Economic Powers Act which authorizes certain personal communications, humanitarian donations, informational materials and travel.

Husch Blackwell’s Export Controls and Economic Sanctions Team continues to monitor developments with regard to Iran and other U.S. export controls and sanctions programs and will provide regular updates as further information becomes available. Should you have any questions related to the JCPOA or other economic sanctions related matters, please contact Cortney Morgan, Linda Tiller, or Grant Leach.

Photo of Cortney Morgan Cortney Morgan

An experienced attorney in the area of international trade and supply chain issues, Cortney advises foreign and domestic clients on all aspects of international trade regulation, planning and compliance, including import (customs), export controls, economic sanctions, embargoes, international trade agreements and preference programs.

Read more about Cortney MorganEmailCortney's Linkedin Profile
Photo of Grant Leach Grant Leach

Grant focuses his practice on international trade, international compliance, securities, mergers, acquisitions and general corporate matters.

Read more about Grant LeachEmailGrant's Linkedin Profile
  • Posted in:
    Business and Commercial
  • Blog:
    International Trade Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo