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On Monday, September 21, 2020, President Trump signed a new Executive Order authorizing the imposition of sanctions on persons engaged in certain conventional arms-related transactions with Iran. The Executive Order, titled “Blocking of Certain Persons with Respect to the Conventional Arms Activity of Iran,” followed Saturday evening’s announcement that the United States would enforce a “snapback” of sanctions under the nuclear treaty with Iran of 2015 (the Joint Comprehensive Plan of Action, or JCPOA).

Autoren: Alexander Brandt Eli Rymland-Kelly Katherine Stavis

In issuing the recent Executive Order, the United States announced that it will enforce the United Nations arms embargo beyond October 18, 2020, the date the embargo is scheduled to expire. Last month, the United Nations Security Council declined to extend the arms embargo beyond that date. The European participants of the JCPOA have since vowed not to cooperate with the United States in its efforts to reimpose the United Nations sanctions.

In conjunction with signing the Executive Order, the Trump Administration designated a number of individuals and entities. Some of these were targeted under Executive Order 13382, an existing authority, which authorizes the imposition of sanctions on proliferators of weapons of mass destruction, while others were targeted under the new Executive Order. Among the designations were an Iranian nuclear agency, the Ministry of Defense and Armed Logistics, entities engaged in ballistic missile activity, and a number of officials and subsidiaries of the Atomic Energy Organization of Iran, which was previously sanctioned in January of 2020. Venezuela’s president, Nicolas Maduro, who was already designated under the Venezuela sanctions program, was also sanctioned under the new Executive Order. Finally, five Iranian nuclear scientists were added to the Entity List, meaning a specific license from the U.S. Department of Commerce is required before any person sells or transfers goods subject to the Export Administration Regulations (which includes almost all U.S.-origin items) to them.