E.O. 13902
US executive order of 5 January 2020 authorising sanctions on additional sectors of Iran's economy.
Last refreshed: 2 May 2026 · Appears in 1 active topic
What legal authority does E.O. 13902 give OFAC over Iranian sanctions evasion?
Timeline for E.O. 13902
OFAC issues GL-W on same Friday
Iran Conflict 2026Mentioned in: OFAC ships paper, Trump signs Cuba
Iran Conflict 2026- What does E.O. 13902 authorise against Iran?
- E.O. 13902, signed 5 January 2020, authorises the US Treasury Secretary to sanction additional sectors of Iran's economy, initially targeting construction, manufacturing, textiles, and mining, under the authority of IEEPA.Source: US Federal Register
- Why was E.O. 13902 signed in January 2020?
- E.O. 13902 was signed days after the US killing of IRGC Quds Force commander Qasem Soleimani, as part of the Trump administration's 'maximum pressure' escalation against Iran.
- How is E.O. 13902 being used in the 2026 Iran conflict sanctions?
- OFAC cited E.O. 13902 alongside E.O. 13224 in its 1 May 2026 General Licence W package, designating Bonyad Mostazafan and the tanker NEW FUSION for Hormuz toll sanctions evasion.Source: OFAC
Background
Executive Order 13902, signed by President Donald Trump on 5 January 2020, expanded the legal basis for US sanctions against Iran by authorising the Treasury Secretary, in consultation with the Secretary of State, to impose sanctions on additional sectors of Iran's economy. The sectors initially targeted included construction, manufacturing, textiles, and mining. The order was part of the Trump administration's "maximum pressure" campaign against Iran and was signed in the immediate aftermath of the killing of IRGC Quds Force commander Qasem Soleimani.
In the context of the 2026 Iran conflict, E.O. 13902 remains one of the two primary legal authorities cited in OFAC enforcement actions. On 1 May 2026, OFAC issued General Licence W and a Hormuz toll alert naming Bonyad Mostazafan and the tanker NEW FUSION as designated under E.O. 13902 and E.O. 13224 simultaneously. The dual citation reflects OFAC's practice of stacking multiple executive-order authorities to maximise legal coverage and deter legal challenges to individual sanctions packages.
E.O. 13902's broad sector-based authority contrasts with the entity-specific approach of earlier Iran sanctions, giving OFAC latitude to reach new categories of Iranian commercial activity as the conflict evolves. Critics, including some legal scholars, have argued that sector-wide sanctions orders exceed the statutory authority granted by Congress under IEEPA and require more explicit legislative backing.
