DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
DETERMINATION PURSUANT TO SECTION 1(a)(i) OF EXECUTIVE ORDER 13902
Automotive and Rail Sectors of the Iranian Economy
Section 1(a)(i) of Executive Order (E.O.) 13902 of January 10, 2020 (“Imposing Sanctions With Respect to Additional Sectors of Iran”) imposes economic sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in such sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State.
To further address the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States described in E.O. 13902, and in consultation with the Department of State and pursuant to 31 CFR § 560.802, I hereby determine that section 1(a)(i) of E.O. 13902...
1) This Determination was issued concurrent with a wave of designations of Iranian entities, in addition to a handful of non-Iranian “[c]ompanies in the Middle East and East Asia [that] export key automotive parts to sustain Iran’s auto industry and evade U.S. sanctions.” This appears to be the first time OFAC has designated third country entities in a pure “secondary sanctions” action where the basis for the designation action was “operating in” an economic sector and such economic sector was not previously subject to a sectoral determination. This case, however, is less harsh than it appears to be at first glance because the Iranian automotive sector was already subject to sanctions (see EO 13846, authorizing sanctions on persons having “significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the automotive sector...