Prohibiting Certain Transactions With Respect to Iran

This executive order imposes a comprehensive trade embargo on Iran, prohibiting U.S. persons from importing Iranian goods, exporting goods or technology to Iran, reexporting U.S.-origin goods to Iran, conducting transactions involving Iranian-origin goods, making new investments in Iran, and facilitating prohibited transactions by foreign affiliates. It builds upon and supersedes earlier limited sanctions from Executive Orders 12613 (1987) and 12957 (March 1995).

Federal Register Open PDF 60 FR 24757

Impact dates

Jun 6, 1995
Export/reexport/transaction prohibitions apply to existing trade contracts; deadline for completing underlying trade transactions under existing letters of credit
May 7, 1995
General prohibitions effective (imports, new investment, facilitation, evasion)

Key directives

Prohibit importation of Iranian-origin goods and services into the United States
Prohibit exportation of goods, technology, and services from U.S. to Iran
Prohibit reexportation to Iran of U.S.-origin goods/technology unless substantially transformed or <10% value
Prohibit transactions by U.S. persons relating to Iranian-origin goods or services
Prohibit new investment by U.S. persons in Iran or Iranian government-controlled property
Prohibit U.S. persons from approving or facilitating prohibited transactions by their foreign affiliates
Authorize Treasury Secretary to promulgate regulations and require reports on oil transactions by foreign affiliates
Revoke inconsistent provisions of Executive Orders 12613 and 12957

Who is ordered

Timeline

Immediate

General prohibition on imports, new investment, and facilitation takes effect May 7, 1995 at 12:01 a.m. EDT

Near term (90d)

Export/reexport/transaction prohibitions take effect June 6, 1995 for existing trade contracts
Letters of credit and financing agreements for existing contracts must complete underlying transactions by June 6, 1995

Long term

Ongoing comprehensive embargo regime
Treasury Department rulemaking and reporting requirements on oil transactions by foreign affiliates

Risks & tensions

Grandfathering of 'existing trade contracts' until June 6, 1995 creates compliance complexity and potential rush to complete transactions
Foreign affiliate reporting requirement on oil transactions may create extraterritorial friction with allied countries
10% de minimis rule for reexports may be difficult to verify in practice
Definition of 'new investment' is broad—covering loans and credit extensions—potentially capturing normal commercial relationships
Explicit carve-out for news publications suggests First Amendment sensitivities in sanctions design