November 24, 2011

The United States and Other Nations Expand Sanctions Against Iran

November 23, 2011
Fulbright Briefing - International Trade
The United States and Other Nations Expand Sanctions Against Iran

On November 21, 2011, the United States announced three measures designed to enhance sanctions on Iran. The President issued an Executive Order authorizing the Secretary of State to impose sanctions on foreign parties that provide goods, services, technology or support of certain value to Iran’s energy or petrochemical sectors; the Secretary of the Treasury designated Iran as a jurisdiction of “primary money laundering concern” under Section 311 of the U.S. Patriot Act; and Treasury’s Office of Foreign Assets Control added Iranian entities and individuals involved in Iran’s suspected nuclear weapons program to the Specially Designated Nationals List.

In announcing these new measures the United States joined the United Kingdom, Canada and the European Union, each of which have implemented, or are planning to implement, additional sanctions on entities in, or doing business with, Iran:

  • The United Kingdom imposed a direction under Schedule 7 to the Counter-Terrorism Act 2008 requiring U.K. credit and financial institutions to cease all business with banks incorporated in Iran, including the Central Bank of Iran (Bank Markazi), and their branches and subsidiaries unless licensed to do so by HM Treasury.[1]
  • Canada issued new sanctions prohibiting financial transactions with Iran, expanding the list of prohibited goods to include all goods used in the petrochemical, oil and gas industry in Iran or items that could be used in Iran's nuclear program, and adding new individuals and entities to the list of designated persons found in Schedule 1 of the Special Economic Measures Act regulations.[2]
  • The European Union has agreed in principle to sanction some 200 Iranian individuals, companies and organizations related to Iran’s nuclear, petrochemical and financial industries. If the E.U. sanctions are implemented as expected, European companies will be banned from doing business with the listed Iranian companies and organizations, and individuals will be subject to asset freezes and Visa bans.

Read the full text of Fulbright's Briefing online.

This article was prepared by Stephen M. McNabb ( or 202 662 4528), Marsha Z. Gerber( or 713 651 5296), Stefan H. Reisinger ( or 202 662 4698) andMary Beth Balhoff ( or 713 651 5652) from Fulbright's International Trade Practice Group. Stephen M. McNabb is a partner in Fulbright’s Washington D.C. office and is Head of Fulbright’s International Trade Practice Group. Marsha Z. Gerber is a partner in Fulbright’s Houston, Texas office and is a member of the International Trade Practice Group. Stefan H. Reisinger and Mary Beth Balhoff are attorneys in the International Trade Practice Group.

Fulbright’s International Trade Practice Group
Fulbright’s International Trade Practice Group is comprised of experienced attorneys in several of Fulbright’s offices throughout the world. Attorneys in the group assist clients in matters concerning international trade laws and regulations; including economic sanctions regulations, export/import control regulations, anti-boycott regulations, and anti-corruption laws.


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