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604. Why do the sanctions set out in E.O.s 13574 and 13590 not appear in E.O. 13846?


The Treasury Department implementation authorities set out in section 1 of E.O. 13574 for “menu-based” sanctions under ISA have been superseded by the implementation authorities for “menu-based” sanctions under a broader range of authorities that include ISA, CISADA, TRA, and IFCA, and section 3 of E.O. 13846 As a result, section 1 of E.O. 13574 is not included verbatim in E.O. 13846. See FAQ 597 and FAQ 598.

The sanctions set out in section 1 of E.O. 13590 — relating to development of petroleum resources in Iran and Iran’s domestic production of petrochemical products — were incorporated into subsections 5(a)(5)-(a)(6) of ISA by a statutory amendment set forth in section 201 of the TRA. As a result, the sanctions previously set forth in section 1 of E.O. 13590 are not included in E.O. 13846, but remain in place pursuant to statutory authorities. Implementation authorities for the sanctions in subsections 5(a)(5)-(a)(6) of ISA are delegated to the appropriate agency heads through the Presidential Memorandum of October 9, 2012, or through section 5 of E.O. 13846.

Date Released
August 6, 2018