Executive Order 13846 (2018)

Executive Order 13846 is a live United States authority that reimposed and consolidated specified Iran-related sanctions after the United States withdrew from the JCPOA. It is part of the legal basis for the United States maximum-pressure sanctions campaign against Iran (2018-2021), but its operation has continued beyond that campaign label.

Authority and effects

The order contains several mechanisms rather than one blanket prohibition. It authorises blocking of property of persons meeting specified criteria, restrictions on correspondent and payable-through accounts of foreign financial institutions, and menu-based sanctions for certain foreign persons. Other provisions address dealings involving Iranian sectors, sovereign debt, petroleum, shipping, insurance and designated persons.

Primary sanctions generally govern United States persons and United States jurisdiction through authorities including the Iranian Transactions and Sanctions Regulations. Secondary sanctions threaten specified consequences for certain conduct by non-United States persons. Blocking, correspondent-account restrictions and menu-based measures have different triggers and effects.

Every application should identify the sector, transaction, actor, knowledge standard, exception, waiver or licence and effective date. A person designated under the order has not thereby been convicted of an offence.

Reimposition and international context

The order followed the United States decision to cease participation in the JCPOA and provided wind-down periods before sanctions were reimposed. This United States reimposition is distinct from the international dispute mechanisms discussed in JCPOA sanctions relief and snapback (2015-2018). The order is not a United Nations Security Council decision and should not be described without qualification as UN snapback.

European responses, including the EU Blocking Statute (Regulation 2271/96), operate through separate jurisdiction and do not erase United States exposure for transactions within the order's scope.

Current status and assessment

As at 30 July 2026, OFAC's current Iran sanctions page continues to identify Executive Order 13846 as an active authority, and 2026 actions have cited it. The consolidated legal text, implementing regulations, current designations and licences must be checked for transaction advice.

Strategic effect should be measured separately from legal reach. Export revenue, investment, compliance withdrawal and diplomatic response can reflect several authorities, market conditions and private decisions. Temporal association with an order does not isolate its contribution to Iranian policy or economic outcomes.

Application sequence

An application begins with the relevant section and defined conduct. The analyst then identifies the actor, transaction date, Iranian counterparty, sector, ownership, knowledge or materiality standard and any exception or licence. Only after those steps can the available blocking, correspondent-account or menu-based consequence be stated.

OFAC designation is an administrative action. Property blocking follows the applicable authority and United States jurisdiction; it is not forfeiture to the government. Foreign financial-institution restrictions may limit correspondent access without blocking every asset of the institution. A warning, investigation, designation and imposed menu sanction are separate stages.

Relief also varies. Waiver, licence, delisting and rescission of an authority have different scope. A policy announcement or negotiation does not suspend the order unless the required legal action occurs. Current list and licence checks therefore remain essential even during diplomatic engagement.

Sources

1. United States Department of the Treasury, Iran sanctions programme (accessed 30 July 2026).
2. Federal Register, Executive Order 13846, 6 August 2018.
3. United States Department of the Treasury, OFAC FAQ 598 (accessed 30 July 2026).
4. Electronic Code of Federal Regulations, 31 CFR Part 560 (accessed 30 July 2026).