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On July 31, 2012, U.S. President Obama signed an Executive Order (E.O.) authorizing additional
sanctions with respect to Iran.
Pursuant to the E.O., the U.S. Secretary of the Treasury and
Secretary of State have been authorized to take action to prevent
Iran from obtaining revenue from petroleum, petroleum products and
petrochemicals for illicit purposes.
The E.O. authorizes the imposition on a foreign financial
institution upon a determination that the foreign financial
institution ". . . has knowingly conducted or facilitated any
significant financial transaction . . . with the National Iranian
Oil Company (NIOC) or Naftiran Intertrade Company (NICO) . . . [or]
for the purchase or acquisition of petroleum or petroleum products
from Iran" through any channel.
The E.O. also brings within the scope of sanctions new authority
to impose sanctions on foreign financial institutions found to have
knowingly conducted or facilitated significant transactions for the
purchase or acquisition of petroleum products from Iran.
Finally, the E.O. provides further authority for Treasury to
block the property and interests in property of any person
determined to have "materially assisted, sponsored, or
provided financial, material, or technological support for, or
goods or services in support of, NIOC, NICO, or the Central Bank of
Iran, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran."
U.S. persons engaged in export transactions and financing of
such transactions should be aware of the breadth and scope of the
sanctions currently extant against Iran (U.S., European Union and
United Nations). When in doubt, they should consider consulting
with cognizant representatives of Treasury's Office of Foreign
Assets Control (OFAC), visiting OFAC's webpage and examining
the various lists that have been promulgated that may have an
impact on export transactions directly or indirectly affecting
Iran. These lists include the Specially Designated Nationals List,
the List of Foreign Financial Institutions Subject to Part 561 (31
CFR), etc.
If you would like further information about
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contact Brian S. Goldstein, any member
of the International Practice Group or the
attorney in the firm with whom you are regularly in
contact.
This article is for general information and does not include
full legal analysis of the matters presented. It should not be
construed or relied upon as legal advice or legal opinion on any
specific facts or circumstances. The description of the results of
any specific case or transaction contained herein does not mean or
suggest that similar results can or could be obtained in any other
matter. Each legal matter should be considered to be unique and
subject to varying results. The invitation to contact the authors
or attorneys in our firm is not a solicitation to provide
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