Why do the sanctions set out in E.O.s 13574 and 13590 not appear in E.O. 13846?
OFAC's answer
The Treasury Department implementation authorities set out in section 1 of E.O. 13574 for “menu-based” sanctions under ISA have been superseded by the implementation authorities for “menu-based” sanctions under a broader range of authorities that include [ISA](https://ofac.treasury.gov/media/5751/download?inline), [CISADA](https://ofac.treasury.gov/media/5691/download?inline), [TRA](https://ofac.treasury.gov/media/5756/download?inline), and [IFCA](https://ofac.treasury.gov/media/5746/download?inline), and section 3 of [E.O. 13846](https://ofac.treasury.gov/media/30181/download?inline) As a result, section 1 of E.O. 13574 is not included verbatim in E.O. 13846. See [FAQ 597](https://ofac.treasury.gov/faqs/597) and [FAQ 598](https://ofac.treasury.gov/faqs/598). The sanctions set out in section 1 of E.O. 13590 — relating to development of petroleum resources in Iran and Iran’s domestic production of petrochemical products — were incorporated into subsections 5(a)(5)-(a)(6) of ISA by a statutory amendment set forth in section 201 of the TRA. As a result, the sanctions previously set forth in section 1 of E.O. 13590 are not included in E.O. 13846, but remain in place pursuant to statutory authorities. Implementation authorities for the sanctions in subsections 5(a)(5)-(a)(6) of ISA are delegated to the appropriate agency heads through the Presidential Memorandum of October 9, 2012, or through section 5 of E.O. 13846.