Executive Order 13846 (2018)

Executive Order 13846 reimposed and consolidated specified United States sanctions against Iran after the United States ceased participation in the JCPOA. Its separate mechanisms restrict property, financial access and specified dealings with Iran. It remains part of the legal framework beyond the United States maximum-pressure sanctions campaign against Iran (2018-2021). The order's reach and the availability of a licence must be analysed separately.

Authority and effects

Signed on 6 August 2018, the order took effect at 12:01 a.m. eastern daylight time on 7 August 2018. Its provisions use different conduct dates: automotive-sector measures began on 7 August, while specified petroleum and petrochemical transactions were covered from 5 November 2018. These dates should not be replaced by the order's signature date. EO 13846, preamble, sections 2(a), 3(a) and 22.

The order contains several mechanisms:

• Section 1 authorises blocking of property within United States jurisdiction or the possession or control of a United States person when Treasury makes the prescribed determination.
• Section 2 authorises restrictions on United States correspondent and payable-through accounts of foreign financial institutions for specified significant transactions. This does not itself block every asset of the institution.
• Sections 3 to 5 provide for selection and implementation of menu-based sanctions. Section 3 assigns the determination to the Secretary of State, in consultation with the officials specified there; section 5 gives Treasury implementation functions for selected financial measures.
• Section 6 permits correspondent-account restrictions or blocking for specified Iranian-rial activity. Section 7 addresses diversion of goods, human rights abuses and censorship. EO 13846, sections 1 to 7 and 14.

Primary prohibitions include restrictions on exports and services by United States persons under the Iranian Transactions and Sanctions Regulations. They also reach certain foreign entities owned or controlled by United States persons; foreign incorporation alone is not a safe harbour. Secondary sanctions involve specified consequences for covered conduct by other foreign persons. The relevant jurisdiction, knowledge standard and sanction must be identified for each provision. 31 CFR 560.204 and 560.215; EO 13846, sections 2, 3, 8 and 16(i).

Exceptions and current licensing position

The order contains provision-specific exceptions. For example, section 2(e) excludes transactions supplying agricultural commodities, food, medicine or medical devices from the specified correspondent-account provisions; it is not a general permission under every Iran sanctions authority. Section 10 addresses a defined natural-gas project exception. Part 560 licences likewise do not displace obligations under other applicable authorities. EO 13846, sections 2(e) and 10; 31 CFR 560.101 and 560.502.

As at 10 November 2026, licensing analysis must account for two recent suspensions. Effective 24 August 2026, OFAC indefinitely stayed sections 560.544, 560.550 and 560.554 and General Licenses F and G, covering specified educational, remittance, conference, sport and academic activities. Effective 8 September 2026, it stayed sections 560.522, 560.528 and 560.529 and General License J-1, covering overflight payments, aircraft safety, bunkering and emergency repairs, and temporary aircraft sojourns. The rules were published on 26 August and 10 September respectively. Publication and operative dates differ. August rule, Dates and Rules To Be Stayed; September rule, Dates and Rules To Be Stayed.

OFAC's accompanying notice records limited wind-down authorisations under General Licenses BB and DD ending on 8 and 23 September 2026 respectively. Its 10 September statement establishes presumed denial for Iran-related specific-licence requests, while allowing consideration where required by law or in exceptional and urgent circumstances. These developments concern the wider Iran programme, not amendments to the text of EO 13846 alone. They do not establish that every humanitarian transaction is prohibited. OFAC suspension notice, pages 1 and 2; licensing policy, paragraphs 1 and 4.

Application and limits

An application should identify the relevant section, actor, counterparty, transaction date, ownership, sector, knowledge or significance threshold, and applicable exception or authorisation. Administrative designation is not a criminal conviction. Blocking restricts dealings but does not transfer ownership to the government. A correspondent-account restriction, blocking determination and selected menu sanction have different effects. EO 13846, sections 1 to 6; OFAC FAQ 9.

The 2018 United States reimposition is distinct from the international mechanisms discussed in JCPOA sanctions relief and snapback (2015-2018). EO 13846 is a presidential order, not a United Nations Security Council decision. For the separate European response, see EU Blocking Statute (Regulation 2271/96). This entry does not assess obligations under that instrument.

This review covers the order's structure and the cited regulatory and licensing developments. It does not provide a complete inventory of current designations, specific licences or every overlapping Iran authority. The eCFR text consulted on 10 November was labelled current through 6 November 2026. A transaction requires a fresh check of operative texts, designations and authorisations. OFAC Iran programme; 31 CFR Part 560.

Strategic effect is a separate analytical question. Export revenue, investment, compliance withdrawal and diplomatic response require evidence capable of separating the order's contribution from other authorities, market conditions and private decisions. Legal reach alone does not establish success in changing Iranian policy.

Sources

1. President of the United States, Executive Order 13846, *Reimposing Certain Sanctions With Respect to Iran*, 6 August 2018, Federal Register 83(152), pages 38939 to 38949, published 7 August 2018. Sections 1 to 10, 14, 16 and 22.
2. United States Department of the Treasury, Office of Foreign Assets Control, Iran sanctions programme and FAQ 598, *What does E.O. 13846 do?*, accessed 10 November 2026.
3. Office of the Federal Register and Government Publishing Office, 31 CFR Part 560, *Iranian Transactions and Sanctions Regulations*, eCFR text current through 6 November 2026, accessed 10 November 2026. Sections 560.101, 560.204, 560.215, 560.501 and 560.502, and the stay notes to the six sections identified above. The eCFR is authoritative but unofficial.
4. Office of Foreign Assets Control, *Iranian Transactions and Sanctions Regulations*, final rule, Federal Register 91, pages 54957 to 54958, 26 August 2026, effective 24 August 2026.
5. Office of Foreign Assets Control, *Iranian Transactions and Sanctions Regulations*, final rule, Federal Register 91, pages 57511 to 57512, 10 September 2026, effective 8 September 2026.
6. Office of Foreign Assets Control, *Suspension of Certain Iranian Transactions and Sanctions Regulations General Licenses*, updated 8 September 2026, pages 1 and 2; *Statement of Licensing Policy on Iran-related Requests*, 10 September 2026. Accessed 10 November 2026.
7. Office of Foreign Assets Control, FAQ 9, *What does OFAC mean when it refers to blocked property?*, updated 21 August 2024, accessed 10 November 2026.