Executive Order 13876 - Imposing Sanctions with Respect to Iran

Date issued: Jun. 24 2019

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TURBOFAC Commentary (1040 words)

Notes:

1) This EO is a hybrid EO that imposes correspondent account or payable-through account ("CAPTA") secondary sanctions (Sec. 2), alongside ordinary IEEPA-based designation criteria and blocking prohibitions (Sec. 1).

As of 8/2019, the EO has not yet been implemented into OFAC's regulations. Notwithstanding the irregularity of the EO as a secondary/primary sanctions hybrid, the EO is otherwise regular in a way that allows for cross-reference to other sets of regulations as a means for discerning the scope and operation of the EO.

2) THE BLOCKING PORTION

Sec. 1 of the EO, read in light of the rest of the EO apart from Sec. 2, is a regular, IEEPA-based blocking program. The EO contains standard derivative designation criteria, standard blocking language, the standard evasion/avoidance prohibition, and, apart from Sec....