Prohibiting Certain Transactions With Respect to the Development of Iranian Petroleum Resources

This executive order declares a national emergency and prohibits U.S. persons from entering into or performing contracts involving overall supervision and management of Iranian petroleum resource development, financing such development, or guaranteeing another person's performance under such contracts. It also prohibits evasion of these restrictions and delegates implementation authority to the Treasury Secretary in consultation with the Secretary of State.

Federal Register Open PDF 60 FR 14615

Impact dates

Mar 16, 1995
Order effective date

Key directives

Prohibit U.S. persons from contracts with overall supervision/management responsibility for Iranian petroleum resource development
Prohibit U.S. persons from financing contracts for Iranian petroleum resource development
Prohibit guaranties of another person's performance under such contracts
Prohibit any transaction evading or avoiding these restrictions
Delegate Treasury Secretary authority to issue regulations and employ IEEPA powers
Effective March 16, 1995 at 12:01 a.m. EST

Who is ordered

Timeline

Immediate

Prohibitions take effect March 16, 1995 at 12:01 a.m. EST
U.S. persons must cease new contracts for Iranian petroleum development supervision/management
U.S. persons must cease new financing contracts for Iranian petroleum development

Near term (90d)

Treasury Secretary to promulgate rules and regulations implementing the order
Potential issuance of licenses and exceptions via regulations/directives

Long term

Ongoing sanctions enforcement against Iranian petroleum sector
Potential expansion or modification via subsequent executive action or legislation (e.g., Iran-Libya Sanctions Act 1996)

Risks & tensions

Ambiguity around 'overall supervision and management responsibility' scope may create compliance uncertainty
No explicit deadline for Treasury regulations—implementation timing unclear
Potential conflict with pre-existing contracts (though order states 'notwithstanding any contract entered into... prior to effective date')
Extraterritorial reach via 'entity owned or controlled by a United States person' may generate international friction
Energy security vs. foreign policy objectives tension for allies dependent on Iranian oil