On January 10, 2020, President Trump issued a new Executive Order (the New EO) expanding secondary sanctions against the construction, mining, manufacturing, and textiles sectors of Iran and providing authority for future sanctions on additional sectors of the Iranian economy.
The New EO authorizes imposition of sanctions on persons facilitating significant transactions in connection with the targeted sectors in Iran (including financial institutions processing such transactions), as well as authorizing the designation of Iranian and other entities operating in those sectors. Like all “secondary” sanctions, the New EO threatens imposition of penalties on non-U.S. persons acting entirely outside U.S. jurisdiction. Together with the concurrently-announced designation of Iran’s largest steel and iron manufacturers, the New EO marks an escalation of the “maximum pressure campaign” against Iran. These expanded sanctions are immediately effective although it is possible that a wind-down window may be provided in future guidance in keeping with previous expansions of U.S. sanctions on Iran.
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