Monthly Archives: October 2017

October 18, 2017

How Trump’s Non-Certification of the Nuclear Agreement and Terrorism Designation of the IRGC will Affect International Business

by Jeremy Paner

Last week, Trump announced that he would not certify Iran’s compliance with the Nuclear Deal. Domestic U.S. legislation (the Iran Nuclear Agreement Act of 2015) requires the President to certify Iran’s compliance with the terms of the deal every 90 days.  The President could, however, sign an Executive Order at any time resuming the sanctions suspended pursuant to the agreement.  In other words, if Trump truly wanted to terminate the agreement with Iran, he could do so unilaterally at his discretion. There are no constraints to his abandoning the agreement.

No Immediate Effect

Trump’s October 13 announcement does not represent an immediate change to the U.S. sanctions targeting Iran.  His non-certification does not terminate the agreement, and the secondary sanctions targeting Iran remain suspended.  Congress will ultimately decide if the United States resumes its suspended sanctions and will expedite consideration of any legislation to reinstate the sanctions if such bills are proposed within 60 days of October 13.  Continue reading