OFAC FAQ #204 · Iran Sanctions
Will Treasury pursue an enforcement action before identifying or listing a person pursuant to Executive Order 13608?
OFAC's answer
The authorities granted under [this Executive Order](https://ofac.treasury.gov/media/5926/download?inline) are in addition to current authorities that Treasury has to pursue an enforcement action for violations of U.S. law, and Treasury is not required to pursue a civil enforcement action prior to identifying or listing a person pursuant to Executive Order 13608.