Executive Order 13645 - Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter-Proliferation Act of 2012 and Additional Sanctions With Respect To Iran

Date issued: Jun. 03 2013

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TURBOFAC Commentary (711 words)

Notes:

1) EO 13645 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 purpose. 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 authoirty under IEEPA. It is also not clear from the text of EO 13846 which of the re-imposed sanctions were actually in...