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EXECUTIVE ORDER
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IMPOSING SANCTIONS WITH RESPECT TO IRAN
By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act 50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), section 212(f) of the Immigration and Nationality Act of 1952 (8 U.S.C. 1182(f)), and section 301 of title 3, United States Code,
I, DONALD J. TRUMP, President of the United States of America, in order to take additional steps with respect to the national emergency declared in Executive Order 12957 of March 15, 1995, in light of the actions of the Government of Iran and Iranian-backed proxies, particularly those taken to destabilize the Middle East, promote international terrorism, and advance Iran's ballistic missile program, and Iran's irresponsible and...
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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....