On May 8, 2018, President Donald Trump announced that the United States was ending its participation in the Joint Comprehensive Plan of Action (JCPOA). The JCPOA is an agreement signed on July 14, 2015, by the United States, Russia, China, France, Britain (all permanent members of the U.N. Security Council), Germany (P5+1), and Iran, to require Iran to limit its nuclear program and, in exchange, require the United States and others to ease economic sanctions affecting Iran's access to some of its hard currency held abroad (see text box, below). The President's decision sets in motion a restoring of U.S. unilateral economic sanctions that will affect U.S. businesses and include secondary sanctions that target commerce originating in other countries that engage in trade with and investment in Iran. The Secretaries of the Treasury and State are required to take appropriate steps to reimpose as quickly as possible, but not later than 180 days, the U.S. sanctions that were waived or lifted in implementing the United States' part of the JCPOA. In addition, the Secretary of Defense is tasked with preparing "to meet, swiftly and decisively, all possible modes of Iranian aggression against the United States, our allies, and our partners. The Department of Defense shall ensure that the United States develops and retains the means to stop Iran from developing or acquiring a nuclear weapon and related delivery systems." To explain how the United States will reestablish the sanctions regime, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a new set of Frequently Asked Questions shortly after the President's announcement. The State Department also reported to Congress a set of waiver revocations, determinations, certifications, and findings to establish, in effect, a timeline for the reimposition of sanctions on certain Iranians and those who engage in business with and investment in Iran. Going forward, the sequence of what may happen next, based on OFAC's FAQs and State Department's reports, includes the following: Treasury establishes two wind-down periods—90 days (August 6, 2018) or 180 days (November 4, 2018)—for those involved in certain commercial or financial activities with Iran to complete those transactions and withdraw. On or after August 6, 2018, OFAC will reimpose sanctions affecting the government of Iran's ability to purchase or acquire U.S. dollars; trade in gold, precious metals, graphite, raw or semi-finished metals, including aluminum and steel, coal, and software; trade in or purchase of the rial ; maintenance of accounts outside of Iran denominated in rial ; trade in Iran's sovereign debt; and trade in Iran's automotive sector. On or after August 6, 2018, OFAC will revoke licenses that allow importation into the United States of Iranian carpets and foodstuffs; and specific licenses that allow export or reexport of commercial aircraft and related parts and services. On or after November 4, 2018, OFAC will reimpose sanctions relating to ports, shipping, shipbuilding; petroleum- and petrochemical-related transactions; transactions between foreign financial institutions and the Central Bank of Iran (CBI) or other Iranian financial institutions; certain specialized financial messaging services; underwriting services, insurance or reinsurance; and Iran's energy sector. On or after August 6 or November 4, depending on how it relates to sectors and other factors described above, the President is expected to reimpose the relevant provisions of several executive orders that were revoked to implement the United States' part of the JCPOA. The President could issue a new executive order, or amend the Executive Order 13716 of January 16, 2016, which revoked the original order (in effect, unrevoking the original language). Effective November 5, 2018, OFAC will revoke previously issued authorizations that were permitted under General License H of January 16, 2016—relating to foreign entities owned or controlled by a U.S. person. No later than November 5, 2018, those individuals and entities removed from the OFAC's Specially Designated Nationals (SDN) list to effectuate the JCPOA will be redesignated, "as appropriate." No later than November 5, 2018, those identified pursuant to Executive Order 13599, relating to trade with Iran's energy and petrochemical sectors, will be moved to the SDN list. They will, however, also have "additional sanctions information—subject to secondary sanctions" attached to their SDN designation. Of particular interest to other countries that purchase oil from Iran is how, or if, the United States will implement secondary sanctions on foreign financial institutions to deter such purchases, as provided for in the National Defense Authorization Act for Fiscal Year 2012. The law requires the President to assess the world petroleum market and whether foreign countries have reduced their consumption of Iran-origin petroleum over the previous six months. If they have not, the United States may deny access to the U.S. financial system. Foreign countries may, however, seek exception. OFAC provides that [t]he State Department will evaluate and make determinations with respect to significant reduction exceptions provided for in section 1245(d)(4)(D) of the NDAA at the end of the 180-day wind-down period. Countries seeking such exception are advised to reduce their volume of crude oil purchases from Iran during this wind-down period. Consistent with past practice, the Secretary of State, in consultation with the Secretary of the Treasury, the Secretary of Energy, and the Director of National Intelligence, would make such determinations following a process of rigorous due diligence. For the initial set of such determinations, the State Department intends to consider relevant evidence in assessing each country's efforts to reduce the volume of crude oil important from Iran during the 180-day wind-down period, including the quantity and percentage of the reduction in purchases of Iranian crude oil, the termination of contracts for future delivery of Iranian crude oil, and other actions that demonstrate a commitment to decrease substantially such purchase. The State Department expects to engage in consultations with countries currently purchasing Iranian crude oil during the 180-day wind-down period. Based on determinations to waive the application of section 1245 from 2012 to 2015, when the JCPOA entered into effect, countries that are possibly facing renewed pressure to reduce their Iranian petroleum consumption include China, India, Japan, Malaysia, Singapore, South Africa, South Korea, Sri Lanka, Taiwan, and Turkey. Countries that benefited from exemptions during that period include Belgium, the Czech Republic, France, Germany, Greece, Italy, Netherlands, Poland, Spain, and the United Kingdom. The regime of economic sanctions against Iran, at its height beginning in 2012, was arguably the most complex the United States and the international community have ever imposed on a rogue state. Iran's economy was once integrated into world trade, markets, and banking. As relations deteriorated, for the United States dating back to Iran's 1979 revolution and hostage-taking at the U.S. embassy, and for the larger international community over more recent human rights, regional stability, and nuclear and missile proliferation concerns, this complete economic integration offered seemingly limitless opportunities to impose economic restrictions and create points where pressure could be applied to bring Iran back into conformity with international norms. Congress remains seized of the matter of Iran's illicit activities, particularly monitoring Iran's reported activities related to military power, international terrorism, terrorism financing, illicit cyber activities, and ballistic missile research and development. Substantive reports required of the administration include the following: In the National Defense Authorization Act for Fiscal Year 2010 ( P.L. 111-84 ; October 28, 2009; §1245; 10 U.S.C. 113 note), as amended, Congress requires the Secretary of Defense to provide a wide-sweeping annual report on the current and future strategy, capabilities, and composition of Iran's military force. In the Intelligence Authorization Act, FY2016 (Division M, Consolidated Appropriations Act for 2016; P.L. 114-113 ; December 18, 2015; §514 [22 U.S.C. 8701 note]), Congress requires the Director of National Intelligence, in consultation with the Secretary of the Treasury, to report regularly to Congress on the monetary value of sanctions relief Iran has received and if it has made use of the funds to support international terrorism, the regime of Bashar al Assad in Syria, nuclear weapons or ballistic missiles development at home or elsewhere, human rights abuses, or personal wealth of any senior government official. In the National Defense Authorization Act for Fiscal Year 2017 ( P.L. 114-328 ; December 23, 2016, §1226), as amended, Congress requires the Secretaries of State and the Treasury, quarterly through 2022, to report on unilateral and multilateral efforts to impose sanctions on entities or individuals connected with Iran's ballistic missile launches. In the Countering Iran's Destabilizing Activities Act of 2017 ( P.L. 115-44 , Title I; §103, 22 U.S.C. 9402), Congress requires the Secretaries of State, Defense, the Treasury, and the Director of National Intelligence to report within 180 days and biennially thereafter a "strategy for deterring conventional and asymmetric Iranian activities and threats that directly threaten the United States and key allies in the Middle East, North Africa, and beyond." In the Countering Iran's Destabilizing Activities Act of 2017 ( P.L. 115-44 , Title I; §104(e), 22 U.S.C. 9403), Congress requires the President to report to Congress within 180 days and every 180 days thereafter on those who contribute to Iran's ballistic missile program. In the Countering Iran's Destabilizing Activities Act of 2017 ( P.L. 115-44 , Title I; §109, 22 U.S.C.