US Sanctions against Iran


On July 23, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Iran-Related Civil Aviation Industry Advisory (the “Advisory”) that provides cautionary guidance to the civil aviation industry on compliance with US sanctions measures targeting Iran.  The Advisory articulates the following key messages: (i) both US and non-US parties in the civil aviation industry remain at risk of US enforcement actions and economic sanctions for engaging in or supporting unauthorized transfers of aircraft or related goods, technology, or services to Iran or to designated Iranian airlines; (ii) the international civil aviation industry stakeholders – including airlines, charter operators, travel distributors and ticket agents, OEMs, suppliers, and service providers – must be on alert for certain deceptive practices used by Iran-related parties to circumvent US sanctions; and (iii) parties should be aware of certain aspects of US sanctions targeting Iran that relate specifically to the civil aviation industry.

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 May 8, 2019, President Trump issued Executive Order 13871 (the “Iran Metals EO”) imposing sanctions on the iron, steel, aluminum, and cooper sectors of Iran subject to a 90-day wind-down period that will expire on August 6, 2019. Although the sale, supply or transfer to/from Iran of steel and aluminum is already targeted by Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012, the Iran Metals EO expands upon those sanctions and further targets the Iranian iron and copper sectors.

The High Representative of the European Union and the Foreign Ministers of France, Germany and the United Kingdom released a joint statement today (see here for the full statement) following Iran’s announcement yesterday that it would withdraw from certain commitments as agreed as part of the 2015 nuclear agreement (see our post here on this). The statement urged Iran to continue to implement its commitments under the nuclear agreement, stating that Iran’s compliance would be…