Executive Order 13949 - Blocking Property of Certain Persons with Respect to the Conventional Arms Activities of Iran

Date issued: Sep. 21 2020

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TURBOFAC Commentary (572 words)

Notes:

1) SEC. 1 DESIGNATION CRITERIA

Except as discussed below Executive Order 13949 is a fully "regular," IEEPA-based, list-based blocking EO that is yet to be incorporated into sanctions regulations. For notes concerning the interpretation of the “basic blocking prohibition” contained in the EO, see General Note on "Abbreviated Regulations" and Executive Orders with Standard Blocking Prohibitions not yet Implemented in the CFR. See also General Note on the Applicability of IEEPA/TWEA Exemptions in EOs and Sanctions Regulations not Specifically Mentioning Them.

Given the broad scope of the designation authorities that apply to ordinary commercial dealings involving Iran in general and the Government of Iran in particular, it may come as a surprise that this sort of “secondary arms embargo” has not already...