Executive Order 13606 - Blocking the Property and Suspending Entry Into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology​ (Effective Date - April 23, 2012)

Date issued: Apr. 23 2012

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TURBOFAC Commentary (996 words)

Notes:

This Executive Order, referred to by OFAC as the "GHRAVITY E.O," is irregular for a few notable reasons.

1) Irregular Derivative Designation Criteria

In addition to the sanctionable "primary conduct" criteria (e.g. operating technology assisting the serious human rights abuses) and the boilerplate derivative designation criteria (i.e. "material assistance" and being "owned or controlled" by a blocked party), the GHRAVITY EO lists as a designation criterion "to have sold, leased, or otherwise provided, directly or indirectly, goods, services, or technology to Iran or Syria likely to be used to facilitate computer or network disruption, monitoring, or tracking that could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria." In FAQ 188, OFAC suggests that this provision can act as a quasi-secondary...