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Executive Order 13622 - Authorizing Additional Sanctions With Respect to Iran
By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), and section 301 of title 3, United States Code,
I, BARACK OBAMA, President of the United States of America, in order to take additional steps with respect to the national emergency declared in Executive Order 12957 of March 15, 1995, as relied upon for additional steps in subsequent Executive Orders, particularly in light of the Government of Iran's use of revenues from petroleum, petroleum products, and petrochemicals for illicit purposes, Iran's continued attempts to evade international sanctions through deceptive practices, and the unacceptable risk posed to the international financial system by Iran's activities, hereby...
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EO 13622 is one of five Iran secondary sanctions related EOs issued between 2011 and 2013 that were either revoked entirely or substantially amended pursuant to the JCPOA in 2016, and of which the substance of the revoked sanctions was reimposed by Executive Order 13846 of August 6, 2018.[1]
The revoked EOs no longer have legal effect, but they can be somewhat useful for interpretive purposes. Executive Order 13846 of August 6, 2018 is extremely unruly, and from the text of it, it is not evident which sanctions are implementations of secondary sanctions statutes, and which are based solely on the President's authority under IEEPA. It is also not clear from the text of EO 13846 which of the re-imposed sanctions were actually in...