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EO 13599Executive OrderObama · D Quiet signal

Executive Order 13599

Blocking Property of the Government of Iran and Iranian Financial Institutions

This executive order blocks all property and interests in property of the Government of Iran, the Central Bank of Iran, and Iranian financial institutions that are in the United States or under U.S. person control. It also authorizes the Treasury and State Departments to implement sanctions and issue regulations, with immediate effect on February 6, 2012.

Federal Register Open PDF 77 FR 6659

Impact dates

  1. Order effective - blocking provisions take effect

Key directives

  • Block all property of Government of Iran, including Central Bank of Iran, in U.S. or under U.S. person control (Section 1(a))
  • Block all property of Iranian financial institutions, including Central Bank of Iran, in U.S. or under U.S. person control (Section 1(b))
  • Block property of persons determined by Treasury (in consultation with State) to be owned/controlled by or acting for blocked persons (Section 1(c))
  • Prohibit donations of articles specified in IEEPA section 203(b)(2) to blocked persons (Section 2)
  • Prohibit contributions/provision of funds, goods, or services to or from blocked persons (Section 3)
  • Prohibit evasion, avoidance, or conspiracy to violate order prohibitions (Section 5)
  • Exempt official U.S. government transactions (Section 6)
  • Authorize Treasury Secretary to promulgate rules and regulations, employ IEEPA powers (Section 9)
  • Authorize Treasury Secretary to exercise NDAA section 1245(d)(1)(A) and 1245(g)(1) functions (Section 10)
  • Authorize State Secretary to exercise NDAA section 1245(d)(4)(D), 1245(e)(1), 1245(e)(2), and 1245(g)(1) functions (Section 11)
  • No prior notice required for listing determinations (Section 8)

Who is ordered

Timeline

Immediate

  • Blocking of Iranian government and financial institution assets effective 12:01 a.m. EST February 6, 2012
  • Prohibition on transfers, payments, exports, withdrawals, or dealings in blocked property

Near term (90d)

  • Treasury/State Department implementation of rules and regulations
  • Potential designations of additional persons under Section 1(c)

Long term

  • Ongoing sanctions enforcement and compliance requirements
  • Potential diplomatic and economic isolation effects on Iran
  • Precedent for future sanctions frameworks

Risks & tensions

  • Potential conflict with international financial institutions over extraterritorial reach
  • Section 13 explicitly frames measures as response to post-1981 Algiers Accords actions, suggesting legal positioning to avoid treaty obligations
  • No prior notice requirement (Section 8) raises due process concerns for affected parties with constitutional presence in U.S.
  • Broad delegation to Treasury and State Secretaries creates significant administrative discretion with limited procedural constraints
  • Carve-out for pre-existing blocked property under Executive Order 12170 (Section 4(b)) creates dual-track asset treatment
Executive Order 13599: Blocking Property of the Government of Iran and Iranian Financial Institutions · Executive Orders