Courts that have addressed takings challenges under IEEPA
81) The attacks on September 11, 2001 ended any chance of reconciliation; a few weeks after the attacks President Bush issued Executive Order 13,224, declaring a national emergency based on his authority under the IEEPA
33) Trade sanctions are enforced through a variety of penalties authorized by IEEPA
C [section][section] 1701--1706 (October 16, 2007), which amended IEEPAs
Section 206 on civil and criminal penalties, is available at: http://www.
Further, numerous IEEPA
and United Nations designations, and active Treasury Department diplomacy, had already changed outsiders' calculations of the risk associated with doing business in Iran even before comprehensive banking and commercial sanctions were fully in place.
The same year, Congress enacted IEEPA
to separately govern the
By enacting IEEPA
, Congress again narrowed the scope of the President's authority under TWEA to only wartime emergencies, and IEEPA
became the primary source for authorizing sanctions during peacetime.
OFAC's primary enforcement actions involve TWEA and IEEPA
, but its authority does extend beyond those acts.
The charge of conspiracy carries a potential sentence of five years in prison, while smuggling carries a potential 10-year prison term, AECA carries a potential 10-year prison term, money laundering carries a potential 20-year prison term and IEEPA
carries a potential 20-year prison term.
The NMLS correctly identified a gap between the nonbinding informational advisories about specific jurisdictions or financial institutions and the powerful authorities available to the secretary under the IEEPA
to impose full-scale sanctions.
functions as a sword wielded against terrorism because it allows the seizure of the assets of terrorist groups and organizations whose funds can be traced to terrorism.
In 1995, President Clinton invoked IEEPA
authority for the first time to target individual terrorists, terrorist groups and their fundraising, rather than countries.