Strictly speaking, the United States extended nothing on 24 August. The power to name sectors has sat inside Executive Order 13902 from the start, and what issued that day was a determination under it. That is your answer, not a quibble: Article 5 reaches requirements resulting from the listed laws or from actions based on them. Listing is not the test, derivation is, so an Annex naming no executive order settles less than it appears to.
Nothing in Regulation 2271/96 obliges you to trade with Iran: the Commission's guidance leaves you free to cease business as you see fit. Ceasing in order to comply is the forbidden act, so your screening file is the exposure, not your decision. In Bank Melli the Court put the burden of proving otherwise on the operator. Your instinct about deliberate omission was the right half to worry about. I have never applied.
Under EU law. Determination, not extension: taken. OFAC signed it pursuant to 31 CFR 560.802, in the ITSR, which the Annex does name. Bank Melli shifts the burden only once evidence points prima facie to compliance, and does not say what a mixed reason must prove. My file records the reason as it is, and if US exposure is in it, I apply under Article 5, second paragraph.
Strictly speaking you corrected me twice. Both stand. 31 CFR 560.802 is the anchor my derivation point never had, the executive order being absent from the Annex. It is a delegation clause in a subpart headed Procedures, so the substance still comes from the order. Article 5 never asks that. It asks what the requirement results from, and a determination signed under a named regulation clears it. Better than you claimed: it also delegates for any further order under the 1995 emergency, so the Annex swallows instruments issued long after it was amended.
Bank Melli, prima facie first: conceded. It stings rather than comforts: your file is the showing.
Practice exists, thinly. A German securities depository was authorised in 2020 and renewed yearly, public only because the blocked counterparty sued. The Court weighed its interests and the Union's, not the counterparty's. Yes or no, nothing between. Write for that reader.
Under EU law. The Commission's template wants the provision, the conduct I intend, and evidence of serious damage to a protected interest. It goes in before the act and suspends nothing: the block stays on until notification. One criterion is whether I could mitigate the damage myself, so my file now records what I rejected. Nothing sets a calendar deadline, and how long one really takes I cannot confirm.