>>5653984 (pp)
Cont'd digging into David S. Cohen:
I'm thinkin' WilmerHale aren't fans of Trump…
https://www.wilmerhale.com/en/insights/client-alerts/iran-sanctions-after-the-trump-administrations-jcpoa-withdrawal
Iran Sanctions After the Trump Administration's JCPOA Withdrawal
"VI. Conclusion
The U.S. withdrawal from the JCPOA greatly complicates diplomatic and commercial activities surrounding Iran. It will likely enhance tensions not only between Iran and the United States, but also between the United States and the EU, and between the United States and countries like Russia and China. Having played a significant hand against the JCPOA, the United States will have to determine whether it will double down in adopting an aggressive enforcement posture, including by imposing secondary sanctions on foreign entities for doing business in Iran. The wind-down periods present an important time for U.S. and non-U.S. companies to assess their exposure to U.S. sanctions against Iran and to prepare for the re-imposition of pre-JCPOA prohibitions."