On September 20, 2019, in response to recent attacks on certain Saudi Arabian oil facilities, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) took action pursuant to Executive Order 13224 against three Iranian entities: (i) the National Development Fund of Iran (“NDF”) (ii) Etemad Tejarat Pars Co., and (iii) the Central Bank of Iran (“CBI”). Executive Order 13224 authorizes the designation of parties if, among other things, they attempt to commit, or pose a significant risk of committing, acts of terrorism.
On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Executive Order 13886 (“EO 13886”), expanding the US counter-terrorism sanctions program by amending Executive Order 13224 (“EO 13224”), which dates to the aftermath of the 9/11 terrorist attacks. OFAC also designated 28 individuals and entities as Specially Designated Global Terrorists (“SDGTs”) under this new authority and updated various other entries on the Specially Designated Nationals and Blocked Persons List to reflect sanction of those authorities under the same authority. In addition, as described in statements here and here, the State Department implemented the new authority by designating Hurras al-Din, an al-Qaeda-affiliated group in Syria, and 12 leaders of SDGT groups (all of which were designated by OFAC on the same day).
On June 24, 2019, the President issued Executive Order 13876, “Imposing Sanctions With Respect To Iran” (“EO 13876”), which specifically imposes sanctions on the Supreme Leader of Iran (currently, Ayatollah Khamenei) and the Supreme Leader’s Office (“SLO”), authorizes the future designation of persons appointed by, or providing support to, the SLO, and designates certain additional senior Iranian Revolutionary Guard (“IRGC”) commanders. While a politically significant and symbolic move, by itself this latest action is unlikely to have much practical impact, except to increase the risk, yet again, of secondary sanctions for non-US parties (particularly financial institutions) that engage in transactions with the targeted parties.
On June 6, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended three Venezuela-related general licenses (re-issued as General License No. 7B, General License No. 8A, and General License 13A) to clarify that these authorizations do not authorize US Persons to engage in transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela. Such general licenses (“GLs”) were originally issued concurrent with the designation of Petróleos de Venezuela SA (“PdVSA”) as a Specially Designated National (“SDN”) on January 28, 2019, under Executive Order 13850. Our original blog post regarding the designation of PdVSA is available here.