Mahsa Amini Human rights and Security Accountability Act (2024 "National Security Supplemental" - Public Law No: 118-50)

Date issued: Apr. 24 2024

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TURBOFAC Commentary (290 words)

Notes:

1) This is one of a dozen or so sanctions related provisions of the 2024 "National Security Supplemental". The Mahsa Amini Human rights and Security Accountability Act calls for the mandatory imposition of IEEPA-based blocking sanctions on any person that falls within a category of Iran-related persons and is affirmatively determined to meet the criteria for (i) designation under one of several pre-existing blocking EOs, or (ii) “Penalties and visa bans applicable with respect to a person pursuant to section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021” (“section 7031(c)”). To the extent that there are “foreign persons” described at section 2(d) that are not yet blocked but do meet the criteria for designation under section 7031(c), this statute would presumably result in the designation of such persons, but otherwise this statute is...