In last month’s newsletter, we discussed how developments in 2012 had considerably tightened sanctions against Iran, including through the first-ever application of sanctions to separately incorporated subsidiaries of U.S. multinational companies. In this second part of our year-end review, we discuss how certain other sanction regimes changed in 2012, including in ways that present both business opportunities (where sanctions have eased) and compliance challenges (where sanctions have been newly imposed or have tightened).