OFAC FAQ (Archived) # 216 - Executive Order 13622, "Authorizing Additional Sanctions With Respect to Iran"

Date issued: Jul. 31 2012

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TURBOFAC Commentary (703 words)

Notes common to FAQs dealing with EO 13622:

1) EO 13622 was the first IEEPA-based (i.e. not mandated by any statute) set of "secondary sanctions," at least in the sense that OFAC uses the term “secondary sanctions,” describing sanctions applicable to conduct with no U.S. nexus that triggers upon an affirmative determination that a person has "knowingly" engaged in "significant" activity. The FFI-based CAPTA sanctions of EO 13622 were implemented in the IFSR at 561.204 in 3/2013. EO 13622 was revoked in 2016, by EO 13716, in connection with the U.S. fulfillments of its commitments pursuant to the JCPOA. This effectively disabled 561.204. During the time the U.S....