Appendix B to Part 562—Executive Order 13871 of May 8, 2019 [Imposing Sanctions With Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran]

Date issued: May. 08 2019

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TURBOFAC Commentary (2062 words)

Notes on EO 13871 and the Implementation of the EO in the IFSR (Part 561) and ISHRASR (Part 562)

1) Like EO 13846, this EO is a hybrid between a "secondary sanctions" authority and an ordinary primary sanctions EO that allows for the "derivative designation" of certain persons in connection with activities that may, and usually will, have no nexus to the U.S. whatsoever.

The issuance of this EO and its eventual implementation into the IFSR (Part 561) and ISHRASR (Part 562) mark a significant shift in the practices of the Executive Branch with respect to the implementation of secondary sanctions authorities. The below discusses major top-level issues pertaining ot the EO and its implementation. For more granular commentary, see comments...