Introduction
Today, June 24, 2019, President Trump signed a new Executive Order (“E.O.”) to impose additional sanctions with respect to Iran. The E.O. primarily targets Iran’s Supreme Leader Ayatollah Ali Khamanei and the Supreme Leader’s Office (SLO) and certain high-level associates and appointees. The sanctions seek to bar those designated pursuant to this E.O. from the international banking and financial system. The Executive Order is not yet numbered and is characterized as simply “Imposing Sanctions with Respect to Iran.” The E.O. is in part in response to Iran’s downing of an American drone last week.
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