Trump Orders US Agencies to Ramp Up Iran Sanctions Enforcement, Rescind GLs
A new national security memorandum signed this week by President Donald Trump orders U.S. agencies to pursue a “maximum pressure” campaign against Iran to stop the country from developing nuclear weapons and supporting terrorism (see 2502040073). It calls on the U.S. to impose new sanctions against the country while stepping up enforcement and possibly revoke any general license or guidance document that gives “Iran or any of its terror proxies any degree of economic or financial relief.”
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The memo specifically orders the Treasury Department to “immediately impose sanctions or appropriate enforcement remedies” against anyone violating Iran-related sanctions and to “implement a robust and continual sanctions enforcement campaign” against Iran. Treasury should also review for “modification or rescission” any general license, frequently asked question or other guidance that gives Iran any financial relief, and it should issue new guidance to the shipping and insurance sectors, as well as port operators, “about the risks to any person that knowingly violates United States sanctions with respect to Iran or an Iranian terror proxy.”
Another provision said the U.S. should “evaluate beneficial ownership thresholds” and analyze whether banks and other financial institutions should be required to adopt a new “‘Know Your Customer’s Customer’ standard” for any transactions related to Iran, which the memo said could prevent sanctions evasion.
The memo also directs the State Department to “modify or rescind” any Iran-related sanctions waivers while working with Treasury to “drive Iran’s export of oil to zero.” The memo especially mentions Iranian crude oil exports to China.
The State Department also should work with Treasury and other agencies to make sure Iran isn’t using the Iraqi financial system to evade sanctions, and that Iran isn’t using Gulf countries as “sanctions evasion transshipment points.”
Another portion of the memo orders the U.S. representative to the U.N. to work with allies to “complete the snapback of international sanctions and restrictions on Iran,” referring to a U.N. process to reimpose sanctions against Iran under the Iran nuclear deal, or Joint Comprehensive Plan of Action (see 2008210009). Rep. Elise Stefanik, R-N.Y., President Donald Trump’s choice for U.N. ambassador, said she would favor reimposing sanctions on Iran for violating its nuclear weapons-related obligations (see 2501230056).