Welcome back to the podcast, bribes, windle, or steel. I'm Alexandra Ragi, and I am delighted to have Amanda Dubusk back on the pot.

Amanda is the chair of DeCard's global international trade and government regulation practice.

She focuses on trade regulations, export controls, trade compliance, and for our purposes today,

sanctions. Thank you for joining me again, Amanda.

Thank you. I'm delighted to be able to do this program.

So international sanctions used to be a fairly sedate area of the law.

There's a lot going on in your world.

Why don't we start with Iran?

May 8th, Trump announced that he's pulling the U.S. out of the JCPOA, the Joint Comprehensive Plan of Action.

Can we start by having you just explain what does it mean to be pulling out? We're pulling out,

we're abandoning. Technically, I think we're actually violating. What has happened with Trump's

announcement? Your statement that it's a really crazy time in sanctions is almost an understatement.

I've been practicing in this area for 30 years, and we have never been in a period

like we're in today. So what it means in terms of the withdrawal is that because the

JCPOA was all set up through executive agreements as opposed to a treaty that's ratified by the Congress.

That means that, again, by executive order, the Trump administration and the president can

just reverse course because it didn't rise to the level of a formal treaty.

So what has happened is that he has reverse course through executive

orders. And what that means is that now full-on sanctions are back on in regards to Iran.

When does this take effect? There's a wind down period. Has that already been triggered or are we still waiting for that?

The wind down period is ongoing.

There's certain things that wind down within 90 days, other things within 180 days.

...