On January 10, 2020, President Trump issued a new Executive Order (the New EO)
expanding secondary sanctions against the construction, mining,
manufacturing, and textiles sectors of Iran and providing authority
for future sanctions on additional sectors of the Iranian economy.
The New EO authorizes imposition of sanctions on persons
facilitating significant transactions in connection with the
targeted sectors in Iran (including financial institutions
processing such transactions), as well as authorizing the
designation of Iranian and other entities operating in those
sectors. Like all "secondary" sanctions, the New EO
threatens imposition of penalties on non-U.S. persons acting
entirely outside U.S. jurisdiction. Together with the
concurrently-announced designation of Iran's largest steel and iron
manufacturers, the New EO marks an escalation of the
"maximum pressure campaign" against Iran. These expanded
sanctions are immediately effective although it is possible that
