However, section 1244 authorizes the President to also block the property of non- US persons that engage in certain transactions with these entities.Īn exception provides that the President is not authorized to block the importation of goods into the United States. Property and interests in property of these entities have already been blocked by other Executive Branch action. Specific entities that the statute designates as covered by this blocking provision include the National Iranian Oil Company (NIOC), National Iranian Tanker Company (NITC), the Islamic Republic of Iran Shipping Lines (IRISL), and their affiliates. Knowingly provides significant support-including financial, material, or technical support, or goods or services-for the benefit of such persons, or for Iranian persons that have been designated as SDNs.Is part of the energy, shipping, or shipbuilding sectors of Iran.Specifically, section 1244 requires the President to block and prohibit all transactions in respect of property of any person he determines: Section 1244 of the NDAA 2013 designates as “entities of proliferation concern” those Iranian organizations that operate ports in Iran and that are involved in the energy, shipping, and shipbuilding sectors of Iran. Sanctions Relating to Iran’s Energy, Shipping, and Shipbuilding Sectors The Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA), signed in August 2012, which codified Executive Order 13599 and expanded the petroleum-related and financial sanctions set forth in the ISA, as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).Īs described in detail below, Subtitle D of the NDAA 2013, the “Iran Freedom and Counter-Proliferation Act of 2012,” expands certain sanctions established by the above-referenced laws, and provides for sanctions covering conduct not previously addressed by Congress or the President.Executive Order 13622, issued in July 2012, imposing sanctions on persons that engage in transactions relating to the purchase of Iranian petroleum, petroleum products, and petrochemical products.

Executive Order 13599, issued in February 2012, which blocked the property of the Government of Iran (GOI), the Central Bank of Iran (CBI), and all Iranian financial institutions.The National Defense Authorization Act for Fiscal Year 2012 (NDAA 2012), signed in December 2011, which imposed sanctions on foreign financial institutions that knowingly conduct or facilitate “significant financial transactions” with the Central Bank of Iran and Iranian financial institutions listed as SDNs.We have previously advised on several of these measures, including, among others: Furthermore, as a new development, the statute purports to authorize the use of monetary penalties available under the International Emergency Economic Powers Act (IEEPA), though as explained below, it is unclear to what extent the President could in practice impose such penalties.Ĭongress and President Obama have been active over the last year in expanding sanctions targeting Iran in response to Iran’s continuing human rights abuses, support for international terrorism, proliferation of weapons of mass destruction, and development of nuclear technology. The types of sanctions that could be imposed for these activities would be those currently available under the Iran Sanctions Act (ISA), as amended, as well as the blocking of property of sanctioned persons in certain cases. Persons involved in the diversion of goods intended for the people of Iran.Persons involved in human rights abuses in Iran.Foreign financial institutions that facilitate financial transactions on behalf of specially designated nationals (SDNs).Persons that provide underwriting services, insurance, or reinsurance relating to sanctionable activities.

Persons that provide precious metals and certain other materials to Iran.

Iran’s energy, shipping and shipbuilding sectors.

The provisions impose more stringent sanctions on: 4310) expanding US extraterritorial sanctions targeting Iran.

On January 2, 2013, President Obama signed the National Defense Authorization Act for Fiscal Year 2013 (NDAA 2013) (H.R.

Ofac iran sanctions ieepa