In the last two weeks, the United States promulgated two legal measures that substantially expand and intensify U.S. sanctions regarding Iran. On 10 August 2012, President Obama signed into law the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “ITRA”). This new legislation followed on an executive order that the President issued on 31 July 2012 (the “31 July Order”).

Overview - In unprecedented ways, the ITRA and the 31 July Order strengthen the posture of the United States in the two main areas of Iran sanctions. First, they take the embargo on Iran-related activity by U.S. companies and individuals about as far as it can go. Second, they expand the types of activity by non-U.S. companies and individuals that can trigger secondary boycott sanctions by the U.S. government. Secondary boycott sanctions are sanctions imposed extraterritorially against particular non-U.S. companies and individuals in response to specified types of activity related to Iran. Secondary boycott sanctions do not involve traditional civil or criminal penalties but instead are measures designed to prevent non-U.S. persons from accessing the U.S. market or conducting business with U.S. persons. In this way, the U.S. “boycotts” these entities based on their involvement with Iran.

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