Imposing Sanctions With Respect to Iran

This executive order blocks all property and interests in property of Iran's Supreme Leader, his office, and associated officials and entities within U.S. jurisdiction. It also authorizes sanctions on foreign financial institutions that conduct significant transactions for these blocked persons, and suspends U.S. entry for covered individuals.

Federal Register Open PDF 84 FR 30573

Key directives

Block all property and interests in property of the Supreme Leader of Iran and the Iranian Supreme Leader's Office
Authorize Treasury, in consultation with State, to designate additional persons appointed by or acting for the Supreme Leader
Authorize sanctions on foreign financial institutions conducting significant financial transactions for blocked persons, including prohibitions or strict conditions on U.S. correspondent and payable-through accounts
Suspend entry into the United States of aliens meeting Section 1 criteria, treating them as covered by Proclamation 8693
Prohibit donations of articles specified in IEEPA section 203(b)(2) to or for benefit of blocked persons
Prohibit any contribution or provision of funds, goods, or services to, by, or for benefit of blocked persons, and receipt of same from such persons
Authorize Treasury to adopt rules and regulations to implement the order
Waive prior notice requirement for listing determinations due to risk of instantaneous asset transfers

Who is ordered

Timeline

Immediate

Property blocking takes effect upon signing for persons listed in Section 1(a)(i)
Entry suspension effective immediately for covered aliens
Prohibitions on transactions and donations effective immediately

Near term (90d)

Treasury/State designations of additional persons under Section 1(a)(ii) criteria
Potential foreign financial institution determinations and correspondent account sanctions under Section 2

Long term

Ongoing sanctions enforcement and compliance by foreign financial institutions
Potential expansion of blocked persons network through cascading designations
Diplomatic and economic pressure on Iran

Risks & tensions

No prior notice requirement (Section 9) raises due process concerns for persons with constitutional presence in U.S.
Broad delegation to Treasury/State for designations creates significant discretionary authority with limited procedural constraints
Cascading designation criteria (Sections 1(a)(ii)(B)-(E)) could sweep in persons with attenuated connections to Supreme Leader
Section 11's reference to 1981 Algiers Accords signals intentional legal positioning regarding U.S.-Iran claims settlement
Foreign financial institution sanctions may create compliance burdens affecting legitimate humanitarian transactions