Executive Order 13902
2020 Trump order authorising sanctions on Iran's economic sectors: construction, mining, energy, metals.
Executive Order 13902, Trump's 2020 sectoral sanctions order for Iran's economy, was used for the fifth time this year on 29 July 2026 to designate a Hormuz marine-insurance network and eight shadow-fleet tankers.
Last refreshed: 17 August 2026 · Appears in 1 active topic
What legal authority does E.O. 13902 give OFAC over Iranian sanctions evasion?
Timeline for Executive Order 13902
Mentioned in: Iran sanctions the register can't find
Iran Conflict 2026Mentioned in: Washington reached for the weaker law
Iran Conflict 2026Treasury names a Hormuz insurance racket
Iran Conflict 2026Mentioned in: OFAC clears 18 duplicates from the list
Iran Conflict 2026OFAC names four in Zanjani network
Iran Conflict 2026Background
Executive Order 13902, signed by President Trump in January 2020 under the International Emergency Economic Powers Act, authorises Treasury to sanction Iran's construction, mining, manufacturing, textiles, metals and energy-intermediary sectors. It is filed under SDN programme code sb0472 as part of the post-nuclear-deal 'maximum pressure' campaign.
Its sectoral design, rather than a list of named entities, is what makes the order durable: Treasury can reach new categories of commercial activity as circumstances change, from Chinese refiners to crypto exchanges to marine insurers, without a fresh executive instrument. That flexibility distinguishes it from Executive Order 13224's terrorism-support basis and Executive Order 13382's WMD-proliferation basis.
OFAC frequently stacks E.O. 13902 with one of the other two orders when a single designation touches both an economic sector and a terrorism or proliferation link, widening the net a single action can catch.
Treasury keeps widening sector sanctions
OFAC's most recent use of E.O. 13902 designated Persian Gulf Marine Insurance Company, HormuzSafe Marine Services Authority and eight shadow-fleet tankers on 29 July 2026. It followed a financial network tied to Babak Zanjani on 24 July, the order's fifth use since April against Chinese refiners, crypto exchanges and LPG shadow-banking networks.
The order's sectoral design, covering construction, mining, energy and metals rather than named entities, lets Treasury reach new categories of commercial activity as the conflict evolves. OFAC has also paired it with the terrorism-support authority behind E.O. 13224 when a single designation, such as the 1 May General Licence W round, touches both an economic sector and a terrorism-finance link.
Hengli became the sanctions test case
E.O. 13902 underwrote OFAC's General Licence V wind-down on Hengli Petrochemical, China's number-two teapot refiner, issued in April 2026 with a 30-day expiry. Beijing's Ministry of Commerce ordered Hengli to ignore the sanctions, and Hengli's Singapore Arm began cutting staff before the Deadline passed.
The order's reach into Chinese commercial refining set the precedent for Treasury's first direct mainland designation, Shanghai Qianye Energy, on 5 June 2026. Together the two actions show E.O. 13902 crossing from Iranian and Shell-company targets into mainland Chinese commercial entities.
What does E.O. 13902 authorise against Iran?
Why was E.O. 13902 signed in January 2020?
How is E.O. 13902 being used in the 2026 Iran conflict sanctions?
What is the difference between E.O. 13902 and NSPM-2 for Iran sanctions?
Why was Persian Gulf Marine Insurance Company sanctioned under E.O. 13902?
