Blocking Property of Certain Persons With Respect to the Conventional Arms Activities of Iran
Executive Order 13949, issued September 21, 2020, authorizes blocking the property of individuals and entities that engage in or materially support Iran’s conventional arms activities. The order targets people who (a) contribute to Iran’s supply, sale, or transfer of arms or related materiel; (b) provide technical training or financial resources to Iran related to arms; (c) engage in activities that proliferate weapons or dual-use items for Iran or its military end-users; (d) assist or sponsor blocked persons; or (e) are owned or controlled by, or act for or on behalf of, blocked persons. It allows the Treasury, in coordination with State, to impose these sanctions and to implement rules to enforce them. The order also imposes immigration restrictions on blocked individuals and clarifies various exceptions and definitions. A notable carve-out permits transactions involving agricultural commodities, food, medicine, and medical devices, and it preserves certain US government and UN activities. The measures are framed as a response to Iran’s post-1981 actions and are implemented under existing sanctions authorities (IEEPA, CAATSA, NA).
Key Points
- 1Blocked persons: The order blocks property of those who (i) help Iran obtain arms or related materiel, (ii) provide arms-related training or services to Iran, (iii) engage in proliferation-related activities for Iran or its military end-users, (iv) materially assist or sponsor blocked persons, or (v) are owned/controlled by or act for blocked persons.
- 2Prohibitions: US persons cannot transfer, pay, export, or otherwise deal in blocked property or provide support to blocked persons; there are reciprocal restrictions on receiving contributions from them.
- 3Immigration restrictions: Blocked individuals face suspension of unrestricted entry into the United States unless the Secretary of State determines otherwise, in consultation with the Attorney General and DHS.
- 4Implementation: Treasury (with State) is empowered to issue rules and regulations to enforce the order; agencies must take appropriate measures to comply.
- 5Humanitarian carve-out: Transactions for agricultural commodities, food, medicine, or medical devices to Iran are not blocked under this order.
- 6Scope and definitions: The order defines terms like “entity,” “Government of Iran,” “Iran,” “person,” and “United States person” to determine who is affected.
- 7Exceptions and national emergency context: The order preserves certain official government and UN activities and notes that measures are part of addressing a national emergency related to Iran’s post-1981 actions.