Frequently Asked Questions

E.O. 13871 authorizes sanctions with respect to the iron, steel, aluminum, and copper sectors of Iran. Section 1 of E.O. 13871 authorizes blocking sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State: (i) to be operating in the iron, steel… Read more

E.O. 13871 became effective upon signing. …

Persons engaged in transactions that could be sanctioned under E.O. 13871 had a 90-day period after the issuance of E.O. 13871 to wind down those transactions without exposure to sanctions under E.O. 13871. Those persons were advised to take the necessary steps to wind down transactions by the end… Read more

Yes. E.O. 13871 expands upon existing sanctions under section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of certain materials, including raw and semi-finished metals such as aluminum and steel, as described in subsections 1245(a)(l)(B) or (C) of IFCA. In… Read more

Yes. The sanctions authorized under E.O. 13871 do not apply to transactions for the conduct of the official business of the United States Government or the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors …

The interpretation of “significant transaction or transactions; significant financial services; significant financial transaction,” as described in the correspondent account sanctions in the IFSR, provides that the Department of the Treasury may consider the totality of the facts and circumstances… Read more

The interpretation of “significant transaction or transactions,” as described in the ISHR provides that the Department of the Treasury may consider the totality of the facts and circumstances and sets forth a list of broad factors that can play a role in the determination whether transactions are… Read more

The term iron sector of Iran means the mining, refining, processing, or manufacturing of iron or iron products in Iran. (31 C.F.R. § 561.336; 31 C.F.R. § 561.317). …

The term steel sector of Iran means the iron-ore smelting, ferrous-scrap melting, refining, processing, or manufacturing of steel or steel products in Iran. (31 C.F.R. § 561.337; 31 C.F.R. § 562.318). …

No. Section 8 of E.O. 13846 continues in effect the prohibition previously contained in section 4 of E.O. 13628, which — consistent with subsection 218(d) of the TRA — provided that civil penalties would not apply if a U.S. person that owns or controls the foreign entity divested or terminated its… Read more