On February 4, 2025, the White House issued a National Security Presidential Memorandum (“NSP Memo”) outlining President Trump’s intention to impose maximum economic and political pressure on the government of the Islamic Republic of Iran (“Iran”), including by enhancing enforcement efforts and modifying or rescinding any existing general license or guidance that provides Iran with “any degree of economic or financial relief.” In addition, on February 6, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced sanctions against an international network involving parties in multiple jurisdictions and several vessels for facilitating the shipment of Iranian crude oil to China.
The NSP Memo directs the Secretary of the Treasury to:
- Impose sanctions or appropriate enforcement remedies on all parties for which Treasury has evidence of US Iran-related sanctions violations;
- Review for modification or rescission any general license or guidance that provides Iran or any of its proxies any degree of economic or financial relief;
- Implement a sanctions enforcement campaign aimed at denying Iran and its proxies access to revenue;
- Issue guidance to the business community flagging the consequences for persons that knowingly violate US Iran-related sanctions; and
- Maintain countermeasures against Iran at the Financial Action Task Force, the global anti-money laundering and terrorist financing watchdog, and assess whether financial institutions should adopt a “Know Your Customer’s Customer” standard for Iran-related transactions.
The NSP Memo also directs the Secretaries of Commerce and State, the Attorney General, and the US Permanent Representative to the United Nations to, among other things:
- Implement a robust export controls enforcement campaign to restrict the flow of military-related technology and components to Iran;
- Modify or rescind existing sanctions waivers that provide Iran any degree of economic or financial relief, and to implement a robust campaign to drive Iran’s export of oil to zero, including in connection with exports of oil to China;
- Investigate, prosecute, and disrupt Iranian sanctions and export control evasion and espionage efforts; and
- Use diplomatic channels to strengthen international sanctions and restrictions on Iran.
OFAC’s February 6 designations targeted entities and individuals in China, India, and the UAE that facilitated the shipment of Iranian crude oil to China on behalf of Iran’s Armed Forces General Staff and a previously sanctioned front company, Sepehr Energy. OFAC also designated four vessels it described as part of Iran’s “shadow fleet.”
We are closely monitoring these developments and will be updating this blog as new developments are announced.
