OFAC guidance on Iran snapback and amended General Licence J

Guidance: OFAC has amended its FAQ on the JCPOA nuclear deal with Iran as to what would happen if there were a “snapback” and sanctions were reintroduced (link here).  The updated answers, M.4 and M.5 say: The US will not retroactively impose sanctions for legitimate activity undertaken after Implementation Day, but the JCPOA does not grandfather contracts signed prior to...