Sanctions On Iran’s Supreme Leader: A Limited Escalation

Law360 (July 8, 2019, 4:24 PM EDT) -- On Monday, June 24, the U.S. Treasury Department’s Office of Foreign Assets Control announced that President Donald Trump had signed Executive Order 13876, which imposes sanctions on Iran’s Supreme Leader Ali Khamenei and on the Supreme Leader's Office, or SLO. The executive order also authorizes the imposition of sanctions against persons related to the SLO.

Although the executive order creates new sanctions authorities under which non-U.S. persons can be sanctioned, the practical impacts are likely to be relatively minimal. Other existing sanctions authorities already authorized the imposition of sanctions on persons related to various individuals and entities associated with the government...

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