On August 10, 2012, President Obama signed into law the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Act”). The passage of the Act, which reflects the strengthening of a comprehensive US Government approach to intensify sanctions against Iran, follows the recent issuance of several Executive Orders that broaden the extraterritorial application of US sanctions against foreign financial institutions (“FFIs”) and non-US entities generally, principally in connection with Iran’s energy and banking sectors, as well as parties designated under the Weapons of Mass Destruction or Terrorism sanctions programs. The Act further expands the scope and coverage of these types of measures. Highlights of the new Act include:
- Expanding the scope of energy-related sanctionable activity by non-US entities as well as available sanctions measures under the Iran Sanctions Act of 1996 (“ISA”), as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”).
- Expanding sanctions against FFIs under both CISADA and the National Defense Authorization Act of 2012 (“NDAA”) in connection with facilitation of significant transactions or providing of significant services to designated financial institutions and persons whose property or interests in property are blocked, as well as financing of petroleum-related transactions.
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