On May 1, 2012, as part of an ongoing US and international campaign to isolate Iran and Syria, President Obama issued Executive Order 13608 expanding the US Treasury Department’s authority to find sanctionable conduct by, and impose sanctions measures against, foreign persons as a result of an expanded range of transactions relating to Iran or Syria.
The Executive Order, entitled “Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria” (the “FSE Order”), allows the Treasury Department’s Office of Foreign Assets Control (“OFAC”) to publicly identify and list foreign persons deemed to have violated, attempted or conspired to violate, or caused a violation of US sanctions laws against Iran and Syria, or to have “facilitated deceptive transactions for or on behalf of persons subject to US sanctions.”1 The FSE Order defines “deceptive transaction” as “any transaction where the identity of any person subject to US sanctions concerning Iran or Syria is withheld or obscured from other participants in the transaction or any relevant regulatory authorities.”
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