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Financial Services Law Insights and Observations

Trump administration's Executive Order 13902 authorizes Iranian industry sanctions

Financial Crimes Department of Treasury OFAC Sanctions Of Interest to Non-US Persons Combating the Financing of Terrorism Executive Order Iran

Financial Crimes

On January 10, the Trump administration issued new sanctions intended to deny the Iranian government revenues from the export of key economic products that may be used to fund its nuclear program.  Specifically, newly-issued Executive Order 13902 authorizes the Secretary of the Treasury, in conjunction with the Secretary of State, to impose asset blocking sanctions on any person determined to operate in the construction, mining, manufacturing or textile sectors of the Iranian economy, or any additional sector as they may jointly determine.  Additionally, EO 13902 authorizes the imposition of certain sanctions on any person determined to have engaged in, or any foreign financial institution determined to have knowingly facilitated, a significant transaction involving one of the aforementioned sectors of the Iranian economy. 

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