Effective July 1, 2013, President Obama's Executive Order 13645 implements certain provisions of the Iran Freedom and Counter-Proliferation Act of 20121 (IFCA) and expands the Iranian sanctions regime to new sectors of Iran’s economic base, including the automotive, energy, and shipping and shipbuilding industries. E.O. 13645 specifically addresses certain types of financial transactions by non-U.S. financial institutions. E.O. 13645 also broadly includes new industries and expands the scope of sanctions against already-targeted sectors like the petrochemical sector.
The desired effect, exacting a deep freeze on already chilly foreign trade with Iran, will likely be accompanied by uncertainty as to what transactions by non-U.S. companies might be considered “significant transactions” and thus within the harsh sanctions of the IFCA and related OFAC regulations.
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