Prohibiting Certain Transactions With Respect to Iran

This executive order consolidates and clarifies existing U.S. sanctions against Iran, prohibiting imports of Iranian goods and services, exports to Iran, new investments by U.S. persons, and related financial transactions. It revokes and replaces overlapping provisions from three earlier executive orders while maintaining their effect on pre-existing transactions.

Federal Register Open PDF 62 FR 44531

Impact dates

Aug 20, 1997
Order effective at 12:01 a.m. EDT

Key directives

Prohibit importation of Iranian-origin goods and services (Sec. 1)
Prohibit exportation/reexportation of goods, technology, services to Iran by U.S. persons (Sec. 2(a)-(b))
Prohibit new investment by U.S. persons in Iran or Iranian government-controlled property (Sec. 2(c))
Prohibit transactions and dealings by U.S. persons related to Iranian goods or exports to Iran (Sec. 2(d))
Prohibit approval/financing/facilitation/guarantee by U.S. persons of foreign person transactions that would be prohibited for U.S. persons (Sec. 2(e))
Prohibit evasion or attempted violation of order (Sec. 2(f))
Continue specific licenses from prior EOs unless revoked/amended by Treasury Secretary (Sec. 3)
Treasury Secretary authorized to promulgate rules, require reports on oil transactions by foreign affiliates (Sec. 5)
Revoke Executive Order 12613 and specified provisions of Executive Order 12959 for post-effective-date transactions (Sec. 7)

Who is ordered

Timeline

Immediate

Effective 12:01 a.m. EDT August 20, 1997: consolidated prohibitions take effect
Prior specific licenses continue unless revoked by Treasury Secretary
Prior general licenses and regulations continue unless inconsistent with this order

Near term (90d)

Treasury Secretary to issue implementing rules and regulations as needed
Reports required from U.S. persons on oil and related transactions by foreign affiliates with Iran

Long term

Ongoing enforcement of Iran sanctions regime
Potential modifications to licenses and regulations by Treasury Secretary

Risks & tensions

Extraterritorial reach (U.S. persons 'wherever located') may create friction with allied jurisdictions
10 percent de minimis rule for foreign-made products creates compliance complexity and potential circumvention risk
Consolidation of three prior orders may create transitional uncertainty for holders of existing licenses
Requirement for U.S. persons to report foreign affiliate oil transactions with Iran imposes surveillance burden on multinational corporations
Explicit carve-out for informational materials reflects First Amendment tension in sanctions law