On May 8th, 2018, the Trump administration withdrew from the Joint Comprehensive Plan of Action or JCPOA and began to reimpose the U.S. nuclear-related sanctions.  All of the sanctions in existence prior to the JCPOA including nuclear-related secondary sanctions will be effective on November 5, 2018.  The wind-down of Iran-related activities pursuant to authorizations provided by the JCPOA is required in two wind-down periods – a 90 day...