The President of the United States, Donald J. Trump recently singed an executive order that re-imposed all sanctions that were lifted or waived in the Joint Comprehensive Plan of Action of July 14,2015. The plan reimposes sanctions on groups and individuals that the Secretary of the Treasure, with the guidance of the Secretary of State finds to be in violation of certain human rights or support of terrorist activities by the Iranian government, its agents, and individuals.
The President signed this executive order to apply financial pressure on the government of Iran with the hopes of swaying the governments’ pursuit of researching and developing newer modern missiles with long range capabilities, its support of terrorist groups, and to stop the activities of the Islamic Revolutionary Guard Corps.
To apply this pressure, the newly signed Executive order prevents the government of Iran from purchasing U.S. Bank Notes or of precious metals. It also applies pressure against persons whom are involved in the energy, shipping, or shipbuilding sectors of Iran if the person is found to have provided significant financial, material, or other support to the government of Iran.
The Secretary of the Treasury, is authorized to impose sanctions to those it deems has violated, including the prohibition of loans from US institutions totaling more than $10,000 in any 12-month period, blocking transfer of credits from the individual, or from restricting or prohibiting the importation of that individual’s goods, technology, or services, just to list a few sanctions.
The Executive Order goes on to further allow the sanctions of individuals who had in some way business dealings with the purchase or sale of the Iranian Rial. It also affects individuals who have maintained the Rial funds in accounts outside of the country of Iran.
The Executive Order also targets the delivery of goods that may be used by the people of Iran that may be used to commit human rights violations and censorships. Such examples of these goods include but are not limited to food, medicine, or medical devices.
This new order was also created to help provide clarity and to consolidate all the relevant authorities into a single document. Because of the complexity of the OFAC sanctions against Iran, this new Executive Order was created to help locate relevant information easier.
One of the purposes of the Executive Order is to help keep the government of Iran, or its agents from censoring the population of Iran. This is because such censorship may lead to abuse of human rights of the people of Iran. This also stretches to individual businesses who work with the government of Iran to help block the transmission of date between the citizens of Iran, those who oppose the public from assembling, and other types of censorship.
What’s important to note, is that the President’s new Executive Order takes place on August 7, 2018 at 12:01 Eastern Daylight Time. However, the sanctions do not take place until the actions are taken after November 5th. 2018. This is because certain sanctions that had been previously lifted would be initiated again 90 days after May 8th, the so called “wind down period”.
Luckily updated OFAC sanctions would still leave the door to applying proper licenses necessary to carry on business. We encourage you to consult with a knowledgeable attorney to continue your business following all the new rules.
This is a legal blog. It is not intended to be used as legal advise. For further information please contact the law offices of attorney Ramona Kennedy.
Ramona Kennedy (Attorney) received her Jurisprudence Doctorate in America and is a licensed attorney in California (USA). Ramona Kennedy is a member of American Immigration Lawyers Association (AILA). Ramona Kennedy is fluent in English and Farsi (reading & writing) & speaks Azeri Turkish.
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