On October 13, 2017, President Trump announced that he would not make a quarterly certification required by the Iran Nuclear Agreement Review Act (“INARA”) because he was unable to certify that the provision of sanctions relief to Iran under the Joint Comprehensive Plan of Action (“JCPOA”) is appropriate and proportionate to the specific and verifiable measures taken by Iran with respect to its nuclear program.  The President’s decision does not immediately result in the reimposition of any Iran-related sanctions or place the United States in breach of its commitments under the JCPOA.  In our memo, we discuss three possible approaches Congress may take in response to the President’s decision, as well as the implications of the decision for future executive branch implementation of the JCPOA and its impact on the other signatories to the agreement and on the regulated public.

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