Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter- Proliferation Act of 2012 and Additional Sanctions With Respect To Iran

This executive order authorizes sanctions against foreign financial institutions and persons that conduct significant transactions related to Iranian currency, support designated Iranian persons, or supply goods and services to Iran's automotive sector. It implements provisions of the Iran Freedom and Counter-Proliferation Act of 2012 and expands existing sanctions authorities, with the order taking effect on July 1, 2013.

Federal Register Open PDF 78 FR 33945

Impact dates

Jul 1, 2013
order effective date

Key directives

Secretary of Treasury authorized to impose sanctions on foreign financial institutions conducting significant rial transactions or maintaining rial accounts outside Iran
Secretary of Treasury authorized to block property of persons materially assisting SDN-listed Iranian persons
Secretary of Treasury authorized to impose sanctions on foreign financial institutions facilitating transactions for Iran's automotive sector
Secretary of State authorized to impose sanctions on persons supplying goods/services to Iran's automotive sector
Secretary of State or Treasury may select from menu of sanctions including loan prohibitions, foreign exchange prohibitions, property blocking, and investment bans
Property blocking for persons engaged in corruption related to diversion of humanitarian goods to Iran since January 2, 2013
Suspension of entry into U.S. for aliens meeting certain criteria
Amendment of EO 13622 to expand petroleum and petrochemical transaction coverage

Who is ordered

Timeline

Immediate

EO signed June 3, 2013
sanctions authorities delegated to Secretaries of Treasury and State

Near term (90d)

order takes effect July 1, 2013 (28 days after signing)
Treasury and State may begin designations under new criteria

Long term

ongoing sanctions implementation and enforcement
potential designations of foreign financial institutions and persons
amendments to EO 13622 remain in effect

Risks & tensions

Potential tension with allies whose financial institutions may be affected by secondary sanctions
Humanitarian exemptions for agricultural commodities, food, medicine, and medical devices may create enforcement complexity
Natural gas trade exception for country-primary-jurisdiction transactions creates monitoring challenges
Vague standard of 'significant transaction' leaves discretion to executive determination
Retroactive application to January 2, 2013 for corruption-related property blocking raises due process considerations addressed by Sec. 15