Client Alert

The Obama Administration Tightens the Screws on Iran, Adopts Far-Reaching New Measures

July 12, 2010

Behnam Dayanim, Michael Oliverio & Ellen N. Walz

On July 1, 2010, President Barack Obama signed into law the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CIS or the Act). Passed with overwhelming bipartisan support, the Act strengthens and broadens the scope of U.S. sanctions policy against Iran. Perhaps most notably, the Act imposes unprecedented obligations on U.S. financial institutions and directs the Director of National Intelligence (DNI) to identify countries that allow diversion of goods to Iran, creating the prospect of additional licensing requirements for exports to those countries.

The CIS follows on the heels of new, tougher United Nations measures. The U.N. sanctions passed by the Security Council on June 9, 2010 focus primarily on Irans nuclear weapons program and target the financial and shipping sectors; the U.N. sanctions also prohibit Iran from buying heavy weapons systems such as helicopters and missiles. The European Union similarly has announced its intention to strengthen European sanctions. In a June 17 declaration, European leaders indicated that the new sanctions will focus on trade insurance, the financial sector and other key industries, such as energy, oil and gas, transportation and shipping.

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