General Note on, and Comparison of, Sections 1(a)(iii) and (a)(iv) of EO 13846 (System Ed. Note)

Last substantive commentary amendment:
Jun. 12 2023

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TURBOFAC Commentary (1547 words)

Consolidated note on, and comparison of, Sections 1 (a)(iii) and (a)(iv) of EO 13846 (System Ed. Note)

UPDATE: *'13599-only bank' is shorthand for Iranian depository institutions whose property and interests in property are (or were) blocked solely pursuant to Executive Order 13599, whether or not they appear on the SDN list. Virtually all such banks are, as of Oct. 8, 2020, blocked pursuant to both EO 13599 and EO 13902 (see Comment on the Designation of the Iranian Financial Sector Pursuant to EO 13902). This comment has not been updated to account for the Oct. 8, 2020 OFAC actions.

Sections 1 (a)(iii) and (a)(iv) of EO 13846 overlap considerably. The following discusses the relationship between the two of them.

SECTION 1(a)(iv)

Section...