639. Why are some persons that had been blocked solely pursuant to E.O. 13599 now designated pursuant to other authorities, such as E.O. 13224 and E.O. 13382?

OFAC designated multiple Iranian financial institutions and other persons previously blocked solely pursuant to E.O. 13599 under E.O. 13224 (relating to counterterrorism), E.O. 13382 (relating to WMD proliferation), and E.O. 13553 (relating to serious human rights abuses by the Government of Iran) on October 16, 2018, and November 5, 2018. These included persons that had been removed from the SDN List on January 16, 2016. As new information became available, OFAC determined that these persons met one or more of the criteria for designation under OFAC’s other designation authorities. Relatedly, a number of persons that were previously designated pursuant to E.O. 13382 and were removed from the SDN List on January 16, 2016 were relisted on the SDN List on November 5, 2018 as persons identified as meeting the definitions of the “Government of Iran” or an “Iranian financial institution” pursuant to E.O. 13599.