OPINION

D.W. NELSON, Senior Circuit Judge:

This case involves an attempt by ten American citizens (hereinafter Lien Claimants) to collect on valid judgments they hold against the Islamic Republic of Iran (Iran) for their injuries arising out of terrorism sponsored by Iran. The Lien Claimants seek to attach a $2.8 million judgment1 that the Ministry of Defense of Iran (the Ministry) obtained in an underlying arbitration with an American company, Cubic Defense Systems, Inc (Cubic).

The district court granted Lien Claimants' motion to attach the Cubic Judgment. The Ministry timely appealed. We have jurisdiction pursuant to 28 U.S.C. § 1291 and we affirm.2

I. Background

Like all foreign states, Iran is protected by sovereign immunity. See Saudi Arabia v. Nelson, 507 U.S. 349, 355, 113 S.Ct. 1471, 123 L.Ed.2d 47 (1993) ("A foreign state is presumptively immune from suit in United States' courts."). Absent an exception to the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. §§ 1602-1611, a foreign state cannot be sued nor can its assets be attached to satisfy a judgment.3 Saudi Arabia, 507 U.S. at 355, 113 S.Ct. 1471. One such exception is for claims arising out of state-sponsored terrorism. 28 U.S.C. § 1605A.

The Lien Claimants hold judgments against Iran based on terrorist activity that Iran sponsored.

Claimant France M. Rafii's father, Dr. Shapoir Bakhtiar, was a former prime minister of Iran. In 1991, Iranian agents murdered Dr. Bakhtiar in his home in Paris, France, because of his political opposition to the Islamic regime. In 2001, Rafii sued Iran under the state-sponsored terrorism exception to the FSIA. Iran did not appear. The district court conducted a two-day bench trial and entered default judgment against Iran for $5 million in compensatory damages (after making the necessary factual, jurisdictional, and statutory findings). The Ministry does not dispute the validity of the judgment.

In 1997, Hamas detonated a suicide bomb at a pedestrian mall in Jerusalem, injuring many American citizens. The Rubin Claimants are a group of nine individuals who either were themselves injured in the bombing, or whose relatives were injured. In 2001, the Rubin Claimants sued Iran for its part in the bombing under the state-sponsored terrorism exception to the FSIA. Iran did not appear. The district court conducted a four-day evidentiary hearing and concluded that Iran provided terrorist training and other material assistance to the bombers. After evaluating all of the Rubin Claimants' compensatory damages, based on each plaintiff's injuries, the district court entered default judgment against Iran and ordered Iran to pay the damages ranging from $2.5 million to $15 million. The Ministry does not dispute the validity of the judgment.

Despite these valid judgments against Iran, Lien Claimants initially lacked any means to collect because the state-sponsored terrorism exception to the FSIA created an anomaly. While the exception abrogated a foreign sovereign's immunity from judgment, it left in place the foreign sovereign's immunity from attachment of its assets.

In 2002, Congress addressed this problem, enacting the Terrorism Risk Insurance Act (TRIA), Pub.L. No. 107-297, § 201, 116 Stat. 2322, 2337 (codified in relevant part at 28 U.S.C. § 1610 note). As originally enacted, section 201(a) provides:

"Blocked" assets include assets "seized or frozen by the United States" under the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. §§ 1701-1706. See TRIA § 201(d)(2). The TRIA therefore permits attachment when it might have otherwise been barred by the FSIA.4

In 1977, Cubic agreed to sell the Ministry an air combat maneuvering range system (ACMR) for $17 million. Additionally, under a separate service contract, Cubic agreed to maintain the ACMR for Iran. By October 1978, Iran had paid over $12 million of the purchase price and modest sums on the service contract. By February 1979, Cubic obtained export permits and was poised to transfer the equipment to Iran.

But, by November 1979, the Iranian revolution had disrupted relations between Iran and the United States. The revolution permanently prevented full performance of the sales and maintenance contracts. Iran and Cubic eventually entered into a modified agreement, under which Cubic would attempt to sell the ACMR to another country. Depending on the result of Cubic's attempt to resell the ACMR, either Iran would be entitled to partial reimbursement for payments it made to Cubic, or Cubic would be entitled to additional payment from Iran.

In the Fall of 1982, Cubic sold the equipment to Canada but ignored Iran's requests for an accounting.

In 1991, pursuant to its contracts with Cubic, Iran initiated arbitration proceedings with the International Chamber of Commerce (ICC). In 1997, the ICC found that Iran and Cubic agreed to discontinue the acquisition and maintenance contracts in light of the revolution, and that they had reached a modified agreement permitting Cubic to sell the equipment to another country. The ICC held that Cubic owed Iran $2.8 million plus interest and costs.

In 1998, the Ministry filed a petition to confirm the arbitration award. The U.S. District Court for the Southern District of California confirmed the award. It entered the Cubic Judgment in August 1999. After the final resolution of this dispute, Cubic deposited funds covering the Cubic Judgment with the Southern District of California.

The Lien Claimants moved to attach the Cubic Judgment. The Ministry opposed Lien Claimants' attempts, arguing: (1) that the Algiers Accords, by which the United States and Iran resolved the Iranian Hostage Crisis, required the United States to protect the Cubic Judgment from attachment; and (2) that the Cubic Judgment was in any event not attachable under the TRIA or any other statute.

The district court granted Lien Claimants' motion to attach. It held that allowing attachment would not violate the United States' obligations under the Algiers Accords because the United States committed only to restore Iran to its pre-November 1979 position. As of 1979, the district court explained, Iran did not have an interest in the confirmed arbitration award.

The district court further held that the Cubic Judgment was a "blocked asset" within the meaning of the TRIA. The court reasoned that the Cubic Judgment was blocked pursuant to President Obama's 2012 Executive Order No. 13359, as well as pursuant to President Bush's 2005 Executive Order No. 13382. It therefore found that the Cubic Judgment was subject to attachment under the TRIA.

In the alternative, the district court held that the Rubin Claimants could attach the Cubic Judgment under 28 U.S.C. § 1610(g), the special attachment provision of the FSIA for creditors holding a Section 1605A terrorism-related judgment against a foreign state.

II. Standard of Review

We review the district court's interpretation of treaties, statutes, regulations, and executive orders de novo. See Motorola, Inc. v. Fed. Express Corp., 308 F.3d 995, 999, n. 5 (9th Cir.2002) (treaties); City of Los Angeles v. United States Dep't of Commerce, 307 F.3d 859, 868 (9th Cir. 2002) (statutes); United States v. Willfong, 274 F.3d 1297, 1300 (9th Cir.2001) (regulations); United States v. Washington, 969 F.2d 752, 754-55 (9th Cir.1992) (executive orders).

III. Discussion

We hold that the United States does not violate its obligations under the Algiers Accords by permitting Lien Claimants to attach the Cubic Judgment. We also hold that the Cubic Judgment is a blocked asset pursuant to President Obama's 2012 Executive Order No. 13359 subject to attachment and execution under the TRIA.

Because it is not necessary to our decision, we do not address whether the Cubic Judgment is also a blocked asset pursuant to President Bush's 2005 Executive Order No. 13382. Similarly, we decline to address the district court's alternative holding that the Rubin Claimants can attach the Cubic Judgment under 28 U.S.C. § 1610(g).

1. Permitting Lien Claimants to attach the Cubic Judgment does not violate the United States' obligations under the Algiers Accords.

The Algiers Accords do not prevent Lien Claimants from attaching the Cubic Judgment because the Ministry's interest in the Cubic Judgment did not arise until after November 14, 1979. As the Supreme Court specifically held in Ministry of Defense & Support for the Armed Forces of the Islamic Republic of Iran v. Elahi, the appropriate property interest to consider is Iran's interest in the Cubic Judgment, which did not arise until 1998. 556 U.S. 366, 376-77, 129 S.Ct. 1732, 173 L.Ed.2d 511 (2009).

In November 1979, Iran took hostages at the American Embassy in Tehran. Invoking the International Emergency Economic Powers Act (IEEPA), President Carter responded by issuing Executive Order 12170, which "blocked all property and interests in property of the Government of Iran." Exec. Order 12170, 44 Fed.Reg. 65729 (Nov. 14, 1979).5

The Department of Treasury promulgated the Iranian Assets Control Regulations to execute President Carter's Executive Order. 31 C.F.R. pt. 535, 44 Fed.Reg. 65279-01 (Nov. 15, 1979). The Regulations provide that "[n]o property subject to the jurisdiction of the United States or which is in the possession or control of persons subject to the jurisdiction of the United States in which on or after the effective date Iran has any interest of any nature whatsoever may be transferred, paid, exported, or withdrawn or otherwise dealt in except as authorized." 31 C.F.R. § 535.201 (2013). The freeze took effect on November 14, 1979.

On January 19, 1981, the United States and Iran settled the hostage crisis and entered into the Algiers Accords. The United States agreed to "restore the financial position of Iran, in so far as possible, to that which existed prior to November 14, 1979." The purpose of the Algiers Accords was to return Iran to the position it was in before President Carter froze Iran's assets in response to the taking of hostages at the American Embassy.

In essence, the Ministry argues that based on a number of factors—most importantly, $12 million in payments Iran made to Cubic on the $17 million sales contract—Iran had a property interest in the ACMR before November 14, 1979. Therefore, according to the Ministry, for the United States to honor its commitments under the Algiers Accords, it must protect the Cubic Judgment from attachment.

But, under the Supreme Court's decision in Elahi, when Iran gained a property interest in the ACMR is irrelevant to our inquiry.

Elahi involved an attempt by a different lien claimant to attach the Cubic Judgment under the TRIA.6 The Supreme Court rejected this Court's determination that the ACMR was the relevant asset at issue. In so holding, the Court explained that the lien claimants in that case did not seek to attach the ACMR, but instead tried to attach the "judgment enforcing [the] arbitration award based upon Cubic's failure to account to Iran for Iran's share of the proceeds of that system's sale." Elahi, 556 U.S. at 376, 129 S.Ct. 1732. The Court explained that Iran's interest in the Cubic Judgment did not arise until 1998, when the district court confirmed the arbitration award. Id.

Further, the Supreme Court explained, even Iran's property interest underlying the Cubic Judgment—the proceeds from the sale to Canada—did not arise until October 1982 at the earliest. Only after Cubic sold the equipment could it "reasonably, comprehensively, and precisely account" for the result of its resale attempts. Id. at 376-77, 129 S.Ct. 1732 (internal quotations omitted).

Under Elahi, Iran did not have an interest in the Cubic Judgment or in the property underlying the judgment until well after the Algiers Accords were consummated. Permitting Lien Claimants to attach the Cubic Judgment would therefore not cause the United States to run afoul of its obligations under the Algiers Accords.7

2. The Cubic Judgment is a blocked asset subject to attachment and execution under the TRIA.

The Cubic Judgment is a "blocked asset" pursuant to President Obama's 2012 Executive Order No. 13539. It is therefore subject to attachment and execution pursuant to the TRIA.

In 2012, President Obama invoked the IEEPA to block "[a]ll property and interests in property of the Government of Iran . . . that are in the United States."8 Exec. Order No. 13359, 77 Fed.Reg. 6659, 6659 (Feb. 5, 2012). However, President Obama's blocking order exempted Iranian property and interests in property that had been blocked in 1979, and that were then unblocked in 1981. 77 Fed.Reg. at 6660.

The Ministry argues that Iran held a property interest in the ACMR that was blocked in 1979 then unblocked in 1981. The Ministry therefore contends that the Cubic Judgment falls within the exemption to President Obama's 2012 Executive Order.

We reject this argument, which just like the Ministry's argument that the Algiers Accords prevent attachment, relies on misidentifying the asset actually at issue in this case.

Under Elahi, the key asset is the one the Lien Claimants seek to attach: the Cubic Judgment, not the ACMR as the Ministry now argues. And the Cubic Judgment does not fall within the exemption to President Obama's blocking order. Iran did not gain a property interest in the Cubic Judgment until 1998, when the district court confirmed the underlying arbitration award. Elahi, 556 U.S. at 376, 129 S.Ct. 1732. Accordingly, Iran's property interest in the Cubic Judgment existed neither in 1979, when Iran's assets were blocked, nor in 1981 when those assets were unblocked. Whether and when Iran gained a property interest in the ACMR is simply not relevant to this case.9

AFFIRMED.