JCPOA Implementation Day Guidance: Section V (Termination of Executive Orders)

V. Termination of Executive Orders

To effectuate the lifting of sanctions set out in sections 4.1 to 4.7 of Annex II of the JCPOA and
described in section II of this Guidance, the United States committed in section 4 of Annex II and
section 17.4 of Annex V of the JCPOA to terminate E.O.s 13574, 13590, 13622, and 13645, and
sections 5-7 and 15 of E.O. 13628. To fulfill this commitment, on Implementation Day, the
President issued an E.O. (the “Termination E.O.”) revoking84 the following:

(i) E.O. 13574 (providing implementation authority for certain menu-based sanctions set
forth in ISA);

(ii) E.O. 13590 (providing for menu-based sanctions with respect to persons who
knowingly sell, lease or provide to Iran goods, services, technology, or support that
could directly and significantly contribute to the maintenance or expansion of Iran’s
domestic production of petrochemical products);

(iii) E.O. 13622 (providing for: sanctions on FFIs that knowingly facilitate significant
financial transactions with NIOC or NICO, or for the purchase or acquisition of
petroleum, petroleum products, or petrochemical products from Iran; sanctions on
persons who knowingly engage in significant transactions for the purchase or
acquisition of petroleum, petroleum products, or petrochemical products from Iran;
and sanctions on persons that have provided material support to NIOC, NICO, or the
CBI, or for the purchase or acquisition of U.S. bank notes or precious metals by the
Government of Iran);

(iv) E.O. 13645 (providing for sanctions relating to: the purchase or sale of the Iranian rial
(or contracts whose value is based on the Iranian rial); significant holdings of the
Iranian rial outside of Iran; Iran’s automotive sector; and persons that have provided
material support to any Iranian person on the SDN List or any other person included
on the SDN List whose property and interests in property are blocked pursuant to
subsection 2(a)(i) of E.O. 13645 or E.O. 13599 (other than an Iranian depository
institution whose property and interests in property are blocked solely pursuant to
E.O. 13599)); and

(v) Sections 5-7 and 15 of E.O. 13628 (providing for: (1) menu-based sanctions with
respect to persons who knowingly, between July 1, 2010, and August 10, 2012: sold,
leased, or provided to Iran goods, services, technology, information, or support that
could directly and significantly facilitate the maintenance or expansion of Iran’s
domestic production of refined petroleum products; sold or provided to Iran refined
petroleum products; or sold, leased, or provided to Iran goods, services, technology,
information, or support that could directly and significantly contribute to the
enhancement of Iran’s ability to import refined petroleum products and (2) certain
amendments to subsections 1(c)(iii), 1(d), and 2(b)(ii) of E.O.13622).

The Termination E.O. also continues in effect implementation provisions for aspects of certain
statutory sanctions that are outside the scope of the U.S. commitment to lift nuclear-related
sanctions under the JCPOA.85

Except as noted above, the Termination E.O. does not affect: (i) the national emergency declared
in E.O. 12957, which shall remain in place, (ii) any E.O. issued in furtherance of that national
emergency other than E.O.s 13574, 13590, 13622, 13628, and 13645, or (iii) the Iranian Assets
Control Regulations, 31 C.F.R. part 535. Further, the revocation of E.O.s 13574, 13590, 13622,
and 13645 and sections 5-7 and 15 of E.O. 13628 will not affect any enforcement action pending
or taken prior to the effective date of the Termination E.O., or any action or proceeding based on
any act committed prior to the date of the Termination E.O.86

For additional information on the Termination E.O., please see JCPOA FAQs A.8 and A.9.

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