Authorizing the Imposition of Certain Sanctions With Respect to the Provision of Goods, Services, Technology, or Support for Iran's Energy and Petrochemical Sectors

This executive order authorizes sanctions against individuals and entities that provide goods, services, technology, or support above specified dollar thresholds to Iran's petroleum development or petrochemical production sectors. The sanctions include blocking property, financial restrictions, export denial, and government procurement bans, and took effect immediately on November 21, 2011.

Federal Register Open PDF 76 FR 72609

Impact dates

Nov 21, 2011
EO effective; sanctions authority active for covered transactions

Key directives

Secretary of State authorized to impose sanctions on persons meeting criteria in section 1
Secretary of State must consult with Secretary of Treasury, Commerce, USTR, Ex-Im Bank President, Fed Chairman, and others
Threshold: $1M+ (or $5M aggregate in 12 months) for petroleum development support
Threshold: $250K+ (or $1M aggregate in 12 months) for petrochemical production support
Relevant agencies shall deny Ex-Im Bank support, export licenses, government procurement, and financial services to sanctioned persons
Secretary of Treasury shall impose financial sanctions including loans over $10M, foreign exchange prohibitions, credit transfer bans, property blocking, and import restrictions
Property blocking effective without prior notice for constitutional-presence persons
Secretary of Treasury authorized to promulgate rules and regulations to implement section 3
All agencies directed to take appropriate measures to carry out provisions

Who is ordered

Timeline

Immediate

EO effective at 12:01 a.m. EST November 21, 2011
Sanctions authority active for transactions on or after effective date
Property blocking without prior notice authorized

Near term (90d)

Secretary of Treasury to promulgate rules and regulations as needed
Agency implementation of sanctions determinations by Secretary of State

Long term

Ongoing sanctions enforcement and determinations
Potential expansion of sanctioned persons list based on conduct

Risks & tensions

Extraterritorial reach may create friction with allied nations whose companies trade with Iran
Threshold-based triggers ($250K/$1M) create compliance complexity for multinational firms
Retroactive nullification of prior contracts/licenses noted but scope of disruption unclear
No prior notice for property blocking raises due process concerns despite stated constitutional-presence finding
Section 9's reference to post-Algiers Accords actions signals political sensitivity around Iran policy legitimacy