On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups.” According to the EO, it is U.S. policy that: (i) Iran be denied a nuclear weapon and intercontinental ballistic missiles; (ii) Iran’s network and campaign of regional aggression be neutralized; (iii) the Islamic Revolutionary Guard Corps (IRGC) and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities; and (iv) Iran’s aggressive development of missiles and other asymmetric and conventional weapons capabilities be countered. 

To impose maximum pressure on Iran, the EO directs various cabinet secretaries to implement measures to impede Iran’s efforts to obtain a nuclear weapon and to counter that country’s malign influence. Among these measures are:

  • Treasury – the imposition of further sanctions on Iran and the implementation of a more robust sanctions enforcement regime;
  • State – the modification or rescission of certain sanctions waivers and the implementation of a robust and continual campaign to drive Iran’s export of oil to zero, including exports of Iranian crude to China;
  • U.S. Ambassador to the United Nations – working with allies to complete the snapback of all international sanctions and restrictions on Iran;
  • Commerce – the conduct of an export control enforcement campaign to restrict the flow of technology and components used by Iran for military purposes; and
  • U.S. Attorney General – the pursuit of all available legal steps to investigate, disrupt, and prosecute financial and logistical networks, operatives, or front groups inside the United States that are sponsored by Iran or an Iranian terror proxy.
Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.