January 2020 Executive Order Imposing Additional Sanctions on Iran

On January 10, 2020, President Trump issued an Executive Order titled, “Imposing Sanctions with Respect to Additional Sectors of Iran.” This Executive Order explicitly targets the construction, mining, manufacturing, and textiles sectors of Iran’s economy, and leaves the door open for the addition of new sectors. The Order authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to impose sanctions on foreign financial institutions that conduct or facilitate any significant financial transaction in connection with these sectors.

The Order also targets any person determined to operate in these sectors, or engage in a significant transaction of goods or services used in connection with these sectors. The Order further extends sanctions to those persons who have assisted, sponsored, or supported such a person. The Order suspends the entry privileges of such persons into the United States, whether as immigrants or nonimmigrants (except where the Secretary of State determines the person’s entry would not be contrary to U.S. interests).

In acknowledgment of the humanitarian sanctions exemptions that exist on paper, the Order’s states that it shall not apply with respect to any person for conducting or facilitating a transaction or sale of agricultural commodities, food, medicine, or medical devices to Iran.

By Amin Bahrami, Legal Fellow