Sanctions Update (September 2012): US Executive Order 13622 and the Iran Threat Reduction and Syria 2012 Human Rights Act of 2012
Type
E-journal
Date
20 Sep 2012
Jurisdiction
Iran, Syria, USA
Taxonomy
Financial Institutions, Financial Services & Activities, Regulation & Offences, Central Government, Companies & Corporate Bodies, Oil & Petroleum, Settlement of International Disputes
Copyright
LexisNexis
Relevant company
Clyde & Co
Analysis
On 30 July 2012, President Obama signed Executive Order 13622 expanding extra-territorial sanctions on Iran's petroleum sales. Eleven days later, the President approved the Iran Threat Reduction and Syrian Human Rights Act, which contains sweeping new and expanded sanctions largely (but not exclusively) targeting Iran's energy sector. These new sanctions apply to both US and non-US persons (individuals, companies and other entities), and significantly broaden the landscape of US sanctions on Iran.
Executive Order 13622: “Authorising Additional Sanctions With Respect to Iran” (EO 13622)
Section 1 of EO 13622 authorises the US Treasury Secretary to impose sanctions against “foreign financial institutions” (including foreign banks) that “knowingly” conduct or facilitate a “significant financial transaction” either (1) with the National Iranian Oil Company or Naftiran Intertrade Company (subject to a limited exception), or (2) “for the purchase or acquisition” of petroleum, petroleum products, or petrochemical products from Iran.