U.S. President Trump Issues Executive Order Imposing Maximum Pressure on Iran

On February 4, 2025, President Donald Trump issued an Executive Order (“E.O.”) to impose “maximum pressure” on the Iranian regime to end its nuclear and missile programs and cease supporting U.S.-designated terrorist groups.

The E.O. orders several components of the U.S. Government to implement new sanctions measures against Iran. We note key measures for your consideration below.

• The E.O. directs the Secretary of the Treasury to impose maximum economic pressure on the Iranian regime, including by sanctioning or imposing enforcement mechanisms on those acting in violation of current US sanctions programs.
• The Secretary of State, in cooperation with the Secretary of Treasury, is directed to modify or rescind existing sanctions waivers to implement a campaign aimed at driving Iranian oil exports to zero.
• The U.S. Permanent Representative to the United Nations is directed to work with key allies to complete the snapback of restrictions and international sanctions on Iran.
• The Attorney General is ordered to pursue any available legal measures to investigate, stop, and prosecute financial networks, front groups, or operatives inside the U.S. that are sponsored by the Iranian regime or an Iranian terror proxy group.

For additional information, we also recommend readers refer to the Fact Sheet issued by the White House on February 4, 2025 in conjunction with this E.O.

Iranian energy exports, which have risen gradually in recent years despite the continuation of U.S. secondary sanctions, are particularly likely to be a focus under the new E.O., and parties involved in such transactions are likely at a substantial risk of U.S. sanctions action.

We will continue to monitor developments in this area and encourage you to subscribe to be kept informed of latest developments. Please contact the authors or your usual Herbert Smith Freehills contacts for more information.