Executive Order 13902

Executive Order 13902, signed by President Trump on 8 January 2020, expanded US sanctions authority over Iran beyond the energy and financial sectors targeted in earlier executive orders. It authorised the Treasury to designate entities operating in Iran's construction, mining, manufacturing, and textiles sectors, and extended that reach to metals, shipping, and industrial intermediaries. The order survived the Biden period intact and is now one of two primary legal instruments OFAC is deploying in the 2026 conflict.

Since February 2026, EO 13902 has been cited in three significant OFAC rounds. On 24 April, it was the authority under SDN programme code sb0472 for the designation of Hengli Petrochemical, China's second-largest teapot refiner. On 2 June, it was cited alongside EO 13224 to freeze Iran's four largest Cryptocurrency exchanges, including Nobitex, with Treasury claiming nearly $500 million in regime-linked digital assets frozen under the Economic Fury campaign. On 5 June, OFAC used EO 13902 to designate an Iranian LPG smuggling and shadow-banking network, including Shanghai Qianye Energy Co Ltd, the first mainland China-domiciled company designated under Iran energy sanctions in the 2026 war.

EO 13902 sits alongside the NSPM-2 framework (which targets missile and drone supply chains) as the two distinct legal architectures underpinning the 2026 sanctions campaign. Its broad sectoral reach makes it the tool of choice when OFAC targets industrial intermediaries, refiners, and commodity brokers rather than proliferation networks.