Frequently Asked Questions

601. Does E.O. 13846 expand the scope of sanctions that were in effect prior to January 16, 2016 (Implementation Day of the JCPOA)?

Answer

Yes. E.O. 13846 broadens the scope of the sanctions that were in effect prior to January 16, 2016 and provides for greater consistency in the administration of Iran-related sanctions provisions. See FAQ 597.

These added measures are as follows:

i. Subsection 1(a)(iii)(B): Providing new authority for blocking sanctions on persons determined, on or after November 5, 2018, to have provided material support for, or goods and services in support of, persons blocked for:
a. Providing material support for, or goods and services in support of, the purchase or acquisition of U.S. bank notes or precious metals by the GOI (i.e., persons designated pursuant to subsection 1(a)(i));
b. Providing material support for, or goods and services in support of, NIOC, NICO, or CBI (i.e., persons designated pursuant to subsection 1(a)(ii)); or
c. Being part of the energy, shipping, or shipbuilding sectors of Iran or a port operator in Iran or knowingly providing significant support to certain other persons blocked pursuant to section 1244(c)(1)(A) of IFCA or to an Iranian person on the SDN List (i.e., persons blocked pursuant to subsection 1(a)(iv) for meeting the criteria of section 1244(c)(1)(A) of IFCA).
ii. Subsection 2(a)(ii): Providing new authority for correspondent and payable-through account sanctions on FFIs determined to have, on or after November 5, 2018, knowingly conducted or facilitated any significant financial transaction on behalf of the persons blocked under the new authorities in subsection 1(a)(iii)(B) described above (i.e., any person blocked pursuant to subsections 1(a)(i), 1(a)(ii), or 1(a)(iv) and included on the SDN List).
iii. Sections 4 and 5: Expanding the menu of sanctions available to impose on persons determined to have, on or after November 5, 2018, knowingly engaged in certain significant transactions relating to petroleum, petroleum products, or petrochemicals from Iran (i.e., persons determined to meet the criteria in subsections 3(a)(ii)-(a)(iii) or to be a derivative thereof pursuant to subsections 3(a)(iv)-(a)(vi)) by authorizing the imposition of:
a. Visa restrictions on corporate officers, principals, or controlling shareholders of a sanctioned person (subsection (4)(e));
b. Any of the sanctions from the menu set forth in subsections 4(a)-(e) on principal executive officers of a sanctioned person (subsection 4(f));
c. Prohibitions on U.S. persons investing in or purchasing significant amounts of equity or debt instruments of a sanctioned person (subsection 5(a)(v)); or
d. Any of the sanctions from the menu set forth in subsections 5(a)(i)-(a)(vi) on principal executive officers of a sanctioned person (subsection 5(a)(vii)).
iv. Section 8: Expanding the prohibition on U.S.-owned or -controlled foreign entities previously contained in section 4 of E.O. 13628 (see FAQs 621-623) by prohibiting transactions with persons blocked for:
a. Providing material support for, or goods and services in support of, Iranian persons on the SDN List and certain other designated persons (i.e., persons designated pursuant to subsection 1(a)(iii)); or
b. Being part of the energy, shipping, or shipbuilding sectors of Iran or a port operator in Iran or knowingly providing significant support to certain other persons blocked pursuant to section 1244(c)(1)(A) of IFCA or to an Iranian person on the SDN List (i.e., persons blocked pursuant to subsection 1(a)(iv) for meeting the criteria of section 1244(c)(1)(A) of IFCA).

Date Released
August 6, 2018