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638. What happened to the E.O. 13599 List?


The E.O. 13599 List was created to clarify that, regardless of their removal from the SDN List on January 16, 2016, persons that OFAC had previously identified as meeting the definition of the terms “Government of Iran” or “Iranian financial institution” still met those definitions and continued to be persons whose property and interests in property were blocked pursuant to E.O. 13599 and section 560.211 of the ITSR. On November 5, 2018, OFAC moved persons identified on the E.O. 13599 List to the SDN List and removed the E.O. 13599 List from its website.
Beginning on November 5, 2018, significant transactions with persons moved from the E.O. 13599 List to the SDN List, other than non-designated Iranian financial institutions, could be subject to secondary sanctions, unless an exception applies, such as the exception relating to transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran; or the significant reduction exception under Section 1245(d)(4)(D) of the NDAA 2012. Persons subject to secondary sanctions will have a notation of “Additional Sanctions Information – Subject to Secondary Sanctions” in the SDN List entry. In addition, effective November 5, 2018, OFAC has amended the ITSR to replace references to the E.O. 13599 List with references to the SDN List.
Some persons moved to the SDN List from the E.O. 13599 List also have been designated under additional authorities and, therefore, have received new unique identification numbers (UIDs) when added to the SDN List. Users of OFAC’s sanctions list data may wish to reference the following mapping table to see how these specific records were added back onto the SDN list.

Date Released
November 5, 2018