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308. What are the implications of the material assistance provision of Executive Order 13645?
Subsection 2(a)(i) of the E.O. authorizes the Department of the Treasury to block the property and interests in property of persons determined to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, (i) Iranian persons included on the SDN List as well as other persons included on the SDN List whose property and interests in property are blocked pursuant to Executive Order 13599, in both cases other than Iranian depository institutions whose property and interests in property are blocked solely pursuant to Executive Order 13599, and (ii) persons whose property and interests in property are blocked pursuant to subsection 2(a)(i) of the E.O. Certain activities relating to the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey are excepted from the material support provision of the E.O.
In implementing this provision, the United States Government will take appropriate steps to avoid, among other things, undue impacts on the access of the people of Iran to humanitarian items, telecommunications, and other basic services. [06-03-13]
1) EO 13685 was revoked in 2016, in connection with the U.S. commitments pursuant to the JCPOA. IFCA-based sanctions imposed by EO 13685 were reimposed by EO 13846, in 2018. See generally comments to EO 13846, and related FAQs. This FAQ was archived in light of the revocation of EO 13685.
Refer to FAQ # 624, and comments thereto, reproducing the contents of this FAQ, but in the context of the reimposition of sanctions in EO 13846.
OCT-17-2020 UPDATE: "Iranian depository institutions whose property and interests in property are blocked solely pursuant to Executive Order 13599" should be amended to account for the blocking of such entities pursuant to both EO 13599 and EO 13902 (see Comment on the Designation of the Iranian Financial Sector Pursuant to EO 13902).