Sanctions Round-Up: Second Quarter 2013

In this issue:

- The Iran Freedom and Counter-Proliferation Act of 2012

- E.O. 13645, issued June 3, 2013

- Enforcement Against Foreign Sanctions Evaders

- Enforcement Against Human Rights Abuses

- New US Sanctions Targeting North Korea

- Evolving US Sanctions Targeting Syria

- Extension but Easing of US Sanctions Targeting Burma

- New General License for US Sanctions Targeting Sudan

- High Profile Settlements

- Sanction Removals

- Online Licensing Tool Launched by OFAC

- Excerpt from: IFCA Provisions Go Into Effect:

As described in our Q4 2012 Sanctions Roundup, the Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”) was signed into law on January 2, 2013 as part of the National Defense Authorization Act for FY 2013 (“NDAA 2013”). Most of IFCA’s provisions, which target specific sectors of Iran’s economy along with the provision of certain goods and services to Iran,1 apply to conduct occurring on or after July 1, 2013. This includes IFCA’s broad prohibitions on activities related to Iran’s energy, shipping, and shipbuilding sectors; the sale of precious or other materials to or from Iran; the provision of underwriting services, insurance, and reinsurance for sanctionable activities related to Iran; and financial transactions involving sanctioned Iranian persons. Under IFCA, foreign financial institutions (“FFIs”) are subject to correspondent account sanctions imposed by OFAC pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”), and non-US persons are subject to sanctions pursuant to the Iran Sanctions Act (“ISA”), as amended, imposed by the State Department.