The Trump Administration issued Executive Order 13846 on August 6, 2018 right at the start of the first wind-down period for U.S. persons to begin ceasing business with Iran.   The key parts of the Order impose blocking sanctions relating to support for the Government of Iran’s purchase or acquisition of U.S. bank notes or precious metals; certain Iranian persons; and Iran’s energy,  shipping, and shipbuilding sectors and port operators.

These new sanctions come in two wind-down phases; one starting August 7, 2018; the other starting November 5, 2018.  The Order provides specifically for the Secretary of the Treasury to require U.S. persons to block (including to refuse to transfer, pay, export, withdraw, or otherwise deal in) all property and interests in property that are in, come within or that come within the possession or control of any U.S. person of such designated person.  Please note these are designations referred to as secondary sanctions.   The U.S. Government can impose these latter sanctions even against parties located outside Iran in instances where the following occurs.

“(i) on or after August 7, 2018, the person has
materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or
services in support of, the purchase or acquisition of
U.S. bank notes or precious metals by the Government
of Iran;
(ii) on or after November 5, 2018, the person has
materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or
services in support of, the National Iranian Oil
Company (NIOC), Naftiran Intertrade Company (NICO),
or the Central Bank of Iran;
(iii) on or after November 5, 2018, the person has
materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or
services to or in support of:
(A) any Iranian person included on the list of
Specially Designated Nationals and Blocked
Persons maintained by the Office of Foreign
Assets Control (SDN List) . . . ; or
(B) any other person included on the SDN List
whose property and interests in property are
blocked pursuant to subsection (a) of this
section or Executive Order 13599 . . . ; or
(iv) pursuant to authority delegated by the
President and in accordance with the terms of such
delegation, sanctions shall be imposed on such person
pursuant to section 1244(c)(1)(A) of IFCA* because the
person:
(A) is part of the energy, shipping, or
shipbuilding sectors of Iran;
(B) operates a port in Iran; or
(C) knowingly provides significant financial,
material, technological, or other support to, or
goods or services in support of any activity or
transaction on behalf of a person determined
under section 1244(c)(2)(A) of IFCA to be a
part of the energy, shipping, or shipbuilding
sectors of Iran; a person determined under
section 1244(c)(2)(B) of IFCA to operate a port
in Iran; or an Iranian person included on the
SDN List (other than a person described in
section 1244(c)(3) of IFCA).”

*ICFA=Iran Freedom and Counter-Proliferation Act of 2012