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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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After a nine-month review, consultations with his national security staff and discussions with members of Congress, President Trump has announced a new U.S. strategy on relations with Iran. In a <a href="https://trumpwhitehouse.archives.gov/the-press-office/2017/10/13/president-donald-j-trumps-new-strategy-iran" target="_blank" rel="noopener">statement</a>, the White House announced that the &ldquo;new Iran strategy focuses on neutralizing the Government of Iran&rsquo;s destabilizing influence and constraining its aggression, particularly its support for terrorism and militants.&rdquo; While not providing specifics, the announcement indicated that the United States would work to deny Iran, and particularly the Islamic Revolutionary Guard Corps (IRGC), funding; counter Iran&rsquo;s efforts to develop its ballistic missiles and other asymmetric weapons capabilities; and &ldquo;deny the Iranian regime all paths to a nuclear weapon.&rdquo;
Regarding the Joint Comprehensive Plan of Action (JCPOA), Trump stated that Iran&rsquo;s &ldquo;activities severely undercut whatever positive contributions to &lsquo;regional and international peace and security&rsquo; [the JCPOA] sought to achieve,&rdquo; adding that Iranian officials have sought to &ldquo;exploit loopholes and test the international community&rsquo;s resolve.&rdquo; While not yet making a full statement on whether he will refuse to re-certify to Congress Iranian compliance under the JCPOA, which must be done by October 15, 2017, Trump clearly indicated that current Iranian behavior cannot be tolerated and that &ldquo;the deal must be strictly enforced, and the IAEA must fully utilize its inspection authorities.&rdquo;
Congressional Activity on Iran
On October 12, 2017, the House Foreign Affairs Committee, chaired by Rep. Ed Royce (R-CA), passed the <a href="http://docs.house.gov/meetings/FA/FA00/20171012/106509/BILLS-115-HR1698-R000487-Amdt-036.pdf" target="_blank" rel="noopener">Iran Ballistic Missiles and International Sanctions Enforcement Act (HR 1698)</a>. The legislation seeks to expand sanctions against Iran for its continuing efforts to develop intercontinental ballistic missile capabilities. In remarks prior to the committee markup of HR 1698, Chairman Royce stated, &ldquo;As flawed as the [JCPOA] deal is, I believe we must now enforce the hell out of it. Let&rsquo;s work with allies to make certain that international inspectors have better access to possible nuclear sites, and we should address the fundamental sunset shortcoming, as our allies have recognized.&rdquo; Committee member statements, witness testimony and a webcast of the October 11, 2017 hearing on the legislation are available on the <a href="https://foreignaffairs.house.gov/2017/10/confronting-full-range-iranian-threats" target="_blank" rel="noopener">House Foreign Affairs Committee&rsquo;s website</a>. The legislation currently has 320 cosponsors in the House of Representatives. HR 1698 will next be reported to the full House for further debate and consideration.
In the Senate, on October 13, 2017, Senators Bob Corker (R-TN) and Tom Cotton (R-AK) announced their intention to introduce legislation to amend the <a href="http://www.thompsonhine.com/uploads/1345/doc/Iran_Nuclear_Agreement_Review_Act_of_2015.pdf" target="_blank" rel="noopener">Iran Nuclear Agreement Review Act of 2015 (Public Law No. 114-17)</a>, to address certain provisions in the JCPOA, particularly an elimination of the deal&rsquo;s sunset on limitations placed on Iran&rsquo;s future development of any nuclear program. The legislation, which has not yet been formally introduced, would penalize Iran if it fails to abide by guidelines related to centrifuge research and development. Ultimately, under the proposed restrictions in the legislation, any violations by Iran could result in the reinstatement of U.S. sanctions, especially if it were to come within a year of gaining nuclear capability.

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President Trump’s “New Strategy on Iran” and Congressional Developments