Frequently Asked Questions

599 … E.O. 13846 is effective at 12:01 a.m. eastern daylight time (EDT) on August 7, 2018. However, certain sanctions set out in E.O. 13846 apply only to activities that take place on or after November 5, 2018, as set out in FAQ 598 above and in the relevant provisions of E.O. 13846. E.O. 13846 is… Read more

600 … Subsection 1(a)(iv) authorizes blocking sanctions pursuant to section 1244(c)(1)(A) of IFCA on persons determined to: (A) be part of the energy, shipping, shipbuilding sectors of Iran; (B) operate a port in Iran; or (C) knowingly provide significant support to certain other persons sanctioned… Read more

601 … Yes. E.O. 13846 broadens the scope of the sanctions that were in effect prior to January 16, 2016 and provides for greater consistency in the administration of Iran-related sanctions provisions. See FAQ 597 . These added measures are as follows: i. Subsection 1(a)(iii)(B): Providing new… Read more

602 … To provide clarity and consolidate relevant authorities into a single document, E.O. 13846 revokes E.O.s 13716 and 13628, and continues in effect relevant provisions from those two revoked E.O.s. See FAQ 597  and FAQ 598 . Provisions of E.O. 13846 that carry forward relevant provisions of E.O… Read more

603 … Yes. OFAC is taking action under section 7 of E.O. 13846 to continue in effect the designations of persons who were designated pursuant to E.O. 13628 at the time of the issuance of E.O. 13846. See FAQ 602 . U.S. persons must continue to block the property and interests in property of these… Read more

604 … 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Department implementation authorities set out in section 1 of E.O. 13574 for “menu-based” sanctions under ISA have been superseded by the implementation authorities for “menu-based” sanctions under a broader range of authorities that include ISA , CISADA , TRA , and IFCA , and… Read more

605 … E.O. 13846 implements provisions of, and provides additional tools related to, ISA , CISADA , TRA , and IFCA that were contained in the prior E.O.s. These include: i. Invoking the President’s authority under the International Emergency Economic Powers Act (IEEPA) to supplement statutory… Read more

606 … After the 90-day wind-down period ends on August 6, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on the purchase or acquisition of U.S. dollar banknotes by the GOI (see, e.g., subsection 1(a)(i) of E.… Read more

190 … U.S. persons who have been issued licenses involving persons designated under the GHRAVITY E.O. should check with the issuing agency regarding the validity of their licenses. … Are existing licenses issued by the U.S. Government involving persons designated under the GHRAVITY E.O. still …

191 … This Executive Order gives Treasury new authorities. First, it strengthens Treasury’s ability to address behavior by foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. This E.O.… Read more