Blocking Property of Certain Persons With Respect to the Conventional Arms Activities of Iran

This executive order authorizes blocking the property of and barring entry to foreign persons and entities involved in Iran's conventional arms trade, including those who supply arms to or from Iran, provide related technical or financial assistance, or materially support sanctioned persons. It expands U.S. sanctions authorities under IEEPA to target Iran's weapons transfers and procurement activities following the expiration of the UN arms embargo.

Federal Register Open PDF 85 FR 60043

Impact dates

Date TBD
Secretary of Treasury to promulgate rules and regulations to carry out order purposes

Key directives

Block all U.S.-jurisdiction property of persons determined to engage in arms transfers to/from Iran (Sec. 1(a)(i))
Block property of persons providing technical training, financial resources, or services related to Iranian arms (Sec. 1(a)(ii))
Block property of persons contributing to proliferation for Iranian government or paramilitaries (Sec. 1(a)(iii))
Block property of persons materially assisting or owned/controlled by blocked persons (Sec. 1(a)(iv-v))
Suspend immigrant and nonimmigrant entry of covered persons (Sec. 3)
Prohibit donations of specified articles to blocked persons (Sec. 5)
Authorize Treasury to issue implementing regulations (Sec. 8)
Exempt agricultural commodities, food, medicine, and medical devices (Sec. 9)
Exempt official U.S. Government and UN transactions (Sec. 10)

Who is ordered

Timeline

Immediate

Property blocking takes effect upon determination by Secretary of State or Treasury
Entry suspension effective immediately for covered aliens
No prior notice required for listings per Section 7

Near term (90d)

Secretary of Treasury to promulgate implementing rules and regulations
Secretary of State to establish procedures for entry suspension exemptions

Long term

Ongoing sanctions designations based on Iran arms activities
Potential expansion of blocked persons network through ownership/control provisions
Enduring restrictions on Iran's conventional weapons access

Risks & tensions

Secondary sanctions risk: Section 1(a)(iv) covers persons assisting blocked persons, creating extraterritorial reach
Vague standard in 1(a)(iii): 'poses a risk of materially contributing' allows preemptive designations
Entry suspension delegation to Secretary of State with broad waiver authority creates implementation uncertainty
Humanitarian exemption (Sec. 9) narrows than full humanitarian carve-out; medical devices included but scope untested
No prior notice requirement (Sec. 7) raises due process concerns for U.S.-connected persons
Explicit disavowal of Algiers Accords relevance (Sec. 11) signals intent to overcome potential legal challenges