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President’s Executive Order – Imposing Sanctions with Respect to Additional Sectors of Iran

 By: Angela Filippi

Law Clerk – Bolour/Carl Immigration Group

 On January 10th 2020, President D. Trump issued an Executive Order (EO) imposing new sanctions on Iran after the recent Iran’s missile attack on Ain al-Assad base in Iraq, where U.S. military forces were stationed.

The President’s response to the attack is entirely economic and it imposes new restrictions on individuals owning, operating, trading with, assisting (and more) some of the principal Iranian industries that generate a substantial amount of incomes in the country each year.

 The sanctioned sectors are construction, mining, manufacturing and textile. Trump’s intent is to isolate Iran by shutting down some of its major companies and additionally to target foreign banks or other foreign institutions having relationships with these sectors by blocking financial operations and exchanges(for instance, it’ll be prohibited, or it’ll be heavily restricted, to maintain a payable account by these institutions in the U.S.). By doing so, the Executive aims to deny Iran revenues that may be used to fund its nuclear program, intercontinental ballistic missile development and terrorism, and also to affect other foreign nations supporting the Iranian economy.

 The sanctions’ main consequence is the restriction of the ability of Iranian businesses and nationals to interact with businesses in the U.S., access to financial institutions in the U.S. and, therefore, to travel to the U.S. under such terms. The EO further establishes that the entrance of individuals involved in the above-mentioned businesses and transactions is suspended, unless the Department of State (DOS) determines that it is not contrary to the interests of the U.S.  

The result will be an increase of denial of immigrant and non-immigrant visas or unreasonable delays in processing applications. DOS usually interprets a visa ban in an exhaustive way, which means that the provision applies to all members of the designated entity (company, partnership, corporation and more, and corresponding agents, shareholders, employees, etc.) Therefore, it is safe to assume that individuals directly involved in the targeted sectors or otherwise parties in financial transactions, donations, sales of goods or services from Iran, representing or acts on behalf of the industries whose interests and affairs are currently blocked, providing supplies, support and technologies, all fall within the sanctions despite contracts or licenses existing prior the executive order.

Since 2017, our office has handled countless waivers for visa applicants subject to the Travel Ban – mostly from Iran.  Please email us for a case evaluation.