Consistent with Section 218 of TRA, section 8 of E.O. 13846 continues in effect the sanctions previously contained in section 4 of E.O. 13628 and expands them to cover activity sanctionable under E.O. 13846 (see FAQ 601). This provision prohibits a U.S.-owned or -controlled foreign entity from knowingly engaging in any transaction, directly or indirectly, with the GOI, or any person subject to the jurisdiction of the GOI, if that transaction would be prohibited by certain Executive orders prohibiting trade and other dealings with, and investment in, Iran and blocking the GOI and Iranian financial institutions, or any regulation issued pursuant to the foregoing (including the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR)), if the transaction were engaged in by a United States person or in the United States. Civil penalties for the U.S.-owned or -controlled foreign entity’s violation of Section 8, attempted violation, conspiracy to violate, or causing of a violation shall apply to the U.S. person that owns or controls such entity to the same extent that they would apply to a U.S. person for the same conduct.
Section 20(c) of E.O. 13846 contains a savings clause that continues in effect under E.O. 13846 regulations, orders, directives, and licenses that were issued pursuant to E.O. 13628 and remained in effect immediately prior to the date of E.O. 13846 Pursuant to this authority, section 560.215 of the ITSR, which implemented section 4 of 13628, and licenses issued pursuant to E.O. 13628 that were valid as of the date of E.O. 13846 remain in effect, subject to their existing terms and conditions. Such terms and conditions include the expiration date of the license