THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 81, July/August 2019

US imposes sanctions on Iranian government officials, Supreme Leader  

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By Michael T. Gershberg, Justin A. Schenck and Avani Uppalapati, Fried Frank www.friedfrank.com   On 24 June 2019, President Trump issued an executive order (‘EO’) imposing new sanctions on Iranian government officials. The EO prohibits transactions with the Supreme Leader of Iran, Ayatollah Ali Khamenei, his office, any government officials appointed by the Supreme Leader, and any directors or officers of designated entities. The EO also authorises secondary sanctions against foreign financial institutions that conduct significant transactions with the newly blocked persons. These new sanctions will have minimal effect on US businesses, which are already broadly prohibited from dealing with...

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