President Obama signed into law on August 10, 2012 the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act). The Act, like the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), broadens the sanctions programs put forth by the Iran Sanctions Act of 1996 (ISA) and otherwise significantly expands the extraterritorial impact of U.S. sanctions.
Key provisions of the Act include:
- Liability of U.S. Firms for Activities of their Non-U.S. Subsidiaries: The Act requires the imposition of civil penalties on U.S. parent firms for the activities of their non-U.S. subsidiaries which, if undertaken in the United States or by a U.S. person, would violate U.S. sanctions law.
- Expansion of Sanctionable Conduct: The Act applies sanctions to any person involved in joint ventures with Iran related to the development of petroleum resources and the mining, production and distribution of uranium, as well as any person transporting or concealing the transport of crude oil from Iran.
- Expansion of Available Sanctions: The Act expands the menu of sanctions available to the President of the United States (President) and the requisite number of sanctions that the President must apply to any person engaging in sanctionable conduct.
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