On January 10, 2020, President Trump issued Executive Order (E.O.) 13902, which authorized the imposition of sanctions on any person determined “to operate in the construction, mining, manufacturing, or textiles sector of the Iranian economy, or any other sector of the Iranian economy as may be determined by the Secretary of Treasury.” On October 8, 2020, the Secretary of Treasury determined that the financial sector of the Iranian economy would also become subject to E.O. 13902, calling it “an additional avenue that funds the Iranian government’s malign activities.”
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On October 8, 2020, the U.S. Secretary of Treasury, Steve Mnuchin designated the financial sector of Iran under Executive Order 13902, putting it into the same category as Iran’s construction, mining, manufacturing and textiles sectors. Pursuant to this determination, the Office of Foreign Assets Control (OFAC) sanctioned 17 Iranian financial institutions for being part of the Iranian financial sector. After November 22, 2020, non-U.S. persons will be exposed to a risk of sanctions if they engage in certain transactions with these Iranian financial institutions or the financial sector. Existing exemptions, including those for imports of food and medicine to Iran, will remain in place.