U.S. Government Implementation of New Iran Sanctions Legislation at the End of September 2010, the U.S
Outbound Trade Compliance Washington, D.C. Client Alert Focus on Iran October 12, 2010 U.S. Government Implementation of New Iran Sanctions Legislation At the end of September 2010, the U.S. Government took several actions to In This Issue: implement the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA"), issuing regulations and making sanctions determinations U.S. Government Implementation of concerning several non-U.S. entities. With these actions, the Obama New Iran Sanctions Legislation Administration has shown its willingness to use the U.S. Government's new Imposition of ISA Sanctions on legislative authority. Companies investing in or doing business with Iran's energy NICO sector should expect to face increasing publicity and scrutiny–official, unofficial, Application of the ISA's "Special formal, and informal–by various parts of the U.S. Government and likely also the Rule" press. New Designations on the SDN List By way of background, CISADA amended the Iran Sanctions Act, 50 U.S.C. § Regulations Implementing 1701 note ("ISA"), to authorize the imposition of sanctions on persons that sell CISADA's Government Contracting refined petroleum products to Iran, support Iran's efforts to develop its domestic Restrictions petroleum refining capabilities, support the enhancement of Iran's ability to import refined petroleum products, or engage in certain other activities in or related to Regulations Implementing CISADA's Codification of the U.S. Iran. Baker & McKenzie previously issued a separate Client Alert on CISADA, Economic Embargo on Iran which can be read here. In August 2010, the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") took a first step to implement CISADA by publishing in the Federal Register the Iranian Financial Sanctions Regulations ("IFSR"), also pursuant to CISADA.
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