Executive Order 13846
August 2018 US Executive Order restoring OFAC secondary sanctions on Iran's energy and financial sectors after the US withdrawal from the JCPOA.
Last refreshed: 7 May 2026 · Appears in 1 active topic
Can EO 13846 survive China's blocking statute making compliance illegal for Chinese firms?
Timeline for Executive Order 13846
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Iran Conflict 2026Beijing flips its blocking statute live
Iran Conflict 2026- What did Executive Order 13846 do to Iran?
- EO 13846, signed August 2018, reimposed US secondary sanctions on Iran's oil, gas, financial and shipping sectors after Trump withdrew from the JCPOA. It gave OFAC authority to sanction any foreign entity transacting with designated Iranian parties.Source: US Federal Register / Lowdown
- Why did China target Executive Order 13846 with its blocking statute?
- China's MOFCOM Announcement No. 21 (2 May 2026) named EO 13846 as an instrument Chinese entities must not comply with, activating blocking rules that allow Chinese firms to sue Western counterparties in Chinese courts for enforcing US Iran sanctions.Source: MOFCOM / Lowdown
- Is Executive Order 13846 still in force in 2026?
- Yes. EO 13846 remained in force as of May 2026 and continued to be the primary legal basis for OFAC's Iran secondary sanctions programme, though China's activation of its blocking statute created a parallel legal challenge.Source: Lowdown
Background
Executive Order 13846, signed by President Trump on 6 August 2018, reimposed the full range of US secondary sanctions on Iran's oil, gas, petrochemical, and financial sectors following the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) in May 2018. The order restored the framework under which OFAC could designate foreign individuals and entities that transact with sanctioned Iranian sectors, creating secondary liability for non-US parties.
The order has been the principal legal instrument authorising OFAC's Iran sanctions programme since 2018, covering major Iranian banks, the Central Bank of Iran, NIOC (National Iranian Oil Company), and the shipping sector. Its energy provisions gave the US the leverage to reduce Iranian oil exports from roughly 2.5 million Barrels Per Day in 2018 to under 300,000 bpd at peak pressure in 2019-2020. Biden-era negotiations sought to revisit it as part of JCPOA revival talks; those talks collapsed without a deal.
In May 2026, China's Ministry of Commerce issued Announcement No. 21 specifically targeting EO 13846 and EO 13902, activating China's blocking statute and creating a direct legal conflict for multinational firms. The order became a flashpoint in the Trump-Xi summit preparation, with Beijing using its challenge to the order as diplomatic leverage ahead of the 14-15 May Beijing meeting.
