Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Sanctions Act of 1996, as Amended

This executive order delegates authority to the Treasury Secretary to implement specific sanctions against persons designated under the Iran Sanctions Act of 1996, including blocking property, restricting financial transactions, and banning imports. It authorizes the administrative machinery to enforce sanctions that Congress had already legislated.

Federal Register Open PDF 76 FR 30505

Impact dates

May 23, 2011
Sanctions take effect upon designation of ISA-sanctioned person

Key directives

Treasury Secretary shall implement five specific sanction types from ISA section 6 upon presidential or State Department determination under ISA section 5
Block all property and interests in property of ISA-sanctioned persons in U.S. jurisdiction
Prohibit U.S. financial institutions from making loans or providing credits to sanctioned persons
Prohibit foreign exchange transactions involving sanctioned persons
Prohibit transfers of credit or payments through financial institutions involving sanctioned persons
Restrict or prohibit imports from sanctioned persons
Prohibit evasion, avoidance, and conspiracy to violate any order prohibitions
No prior notice required for property blocking measures
Treasury Secretary authorized to promulgate rules and regulations
All agencies directed to take appropriate measures to carry out order

Who is ordered

Timeline

Immediate

Sanctions prohibitions take effect upon designation of ISA-sanctioned persons
Property blocking authority active without prior notice

Near term (90d)

Treasury/State Department implementation of rules and regulations
Agency coordination to establish enforcement mechanisms

Long term

Ongoing sanctions enforcement against Iran-related entities
Potential expansion of designated persons under ISA section 5

Risks & tensions

Delegated authority creates tension between presidential control and Secretary of State operational independence in designations
No prior notice provision (Sec. 4) raises due process concerns for affected persons with constitutional U.S. presence
Broad definition of 'financial institution' and 'U.S. person' creates extraterritorial compliance burden for foreign branches
Section 7 disclaimer attempts to limit legal challenge scope by tying sanctions to post-1981 actions
Vague 'appropriate measures' language for agency implementation leaves enforcement consistency uncertain