As everyone knows by now, the so-called “Iran Deal” reached its implementation day on January 16, 2016. For all the controversy surrounding the deal, American exporters might suppose that US sanctions against their trading with Iran had been lifted. In fact, however, the sanctions the Obama Administration has relaxed are almost exclusively the “secondary sanctions” it imposed on third-country traders and financial institutions to induce the rest of the world ratchet up the pressure that finally brought Iran to the nuclear negotiation table.
To be sure, Americans are now free to import Iranian carpets, pistachios and caviar – but that’s it, so far as newly-authorized US-person activities are concerned. And the thing to remember is: As much as things may have changed for the rest of the world, the US prohibitions on American transactions with Iran and its nationals remain very much in place.