The Trump Administration is poised to announce its position on staying in or withdrawing from the Joint Comprehensive Plan of Action (JCPOA) ahead of the date for Iran sanctions renewal of waivers on May 12. If the President selects not to renew sanctions waivers by May 12 then those sanctions will come back into force against foreign financial institutions (FFIs) that engage in "significant financial transactions" with Iran's Central Bank. The sanctions apply to FFIs that are central banks only if the financial transactions with Iran's Central Bank concern oil purchases. Applicable sanctions include prohibiting FFIs from opening accounts in the U.S. or imposing strict limitations on their existing accounts in the U.S. Thus, an FFI caught can be denied access to the US financial system and the ability to process USD payments.