During his presidential campaign, President-Elect Donald Trump made few concrete statements regarding sanctions policies. However, it is possible to identify some areas where things might change significantly.

Iran: President-Elect Trump has said that he would immediately scrap the Joint Comprehensive Plan of Action (JCPOA) with Iran. The JCPOA has been described as a political commitment rather than a legal agreement. Under U.S. law, the President could accordingly modify the commitments of the United States, or even withdraw the United States from the Agreement completely, by his own action. Among other measures, the United States could re-impose a range of secondary sanctions against Iran, including those applying to financial and banking transactions; transactions involving the energy, shipping and shipbuilding, and other sectors; and trade in certain materials like steel. From the perspective of U.S. companies, the most likely and far-reaching change would be the revocation of General License H, which allows the foreign subsidiaries of American companies to do some types of business with Iran. The re-application of secondary sanctions could have a major effect on U.S. relations with major trading partners, especially the European Union, which has dismantled most of its sanctions against Iran. It is likely that the EU in particular would argue strongly against any proposed re-expansion of U.S. sanctions against Iran. Warnings from the U.S. intelligence community that terminating the JCPOA would have adverse security consequences may also affect decisions regarding the JCPOA.

Russia: President-Elect Trump has emphasized that he wants to establish better relations with Russia. This could potentially lead to a loosening or even dismantling of U.S. sanctions against Russia. That said, the United States has worked closely with the EU to coordinate policy regarding Russia, which could act as a brake on changes.

Cuba: Following the death of Fidel Castro, President-Elect Trump threatened to reverse liberalization of U.S. sanctions against Cuba unless there was a “better deal for the Cuban people.” While the liberalization of U.S. sanctions against Cuba has been unpopular with some segments of the Republican Party, American businesses have already begun to take advantage of relaxed sanctions, and would probably oppose any renewed restrictions. The most likely outcome is the maintenance of the status quo, but little if any additional action regarding Cuba.

General U.S. Policy: One of the pillars of the Trump campaign was a desire for a less-interventionist U.S. foreign policy. Taken at face value, this would indicate that, under President Trump, the United States might be more reluctant to impose sanctions as a tool of foreign policy. This is especially true with respect to human rights issues. As always with a new administration, though, mostly we will have to wait and see, first who is appointed to key positions such as Secretary of State, and second, what the new Trump Administration actually does.