Category: Trade Security

Of particular interest, an Executive Order will establish a new economic sanctions program to “block the property of and prohibit transactions with significant transnational criminal networks that threaten national security, foreign policy, or economic interests.”

This announcement will be of interest to companies engaged in international trade as we as financial institutions located throughout the world. There is also a Foreign Corrupt Practices Act component. The White House report is available for download here.

We will be sending to our clients a detailed analysis of this new strategy. It will summarize how it will impact their compliance and other business considerations. Please contact us if you are interested in learning more about this or how we can assist your company with your federal regulatory or business needs.

The public has until Tuesday, September 13, 2011, to submit comments on the proposed EAR revisions. For more information, you can download the Federal Register notice here. 

The Congress directed the GAO to “review issues related to Iran’s monitoring, filtering, and disruption of information and communications flows in two mandates: (1) Section 106 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) requires us to review a procurement ban against entities that export technologies to the Iranian government for monitoring, filtering, and disrupting informationandcommunicationsflows, and (2) Senate Report 111-201 related to the Ike Skelton National Defense Authorization Act for Fiscal Year 2011 directs us to identify entities that have a financial interest in the development of Iran’s ability to monitor, filter, and disrupt information and communication flows and determine which entities have contracts with the U.S. government.”

The report is available for dowload here.

“The steps we have taken this week seek to limit Iran’s ability to use the global financial system to pursue illicit activities. We have made important progress in isolating Iran, but we cannot waver. Our efforts must be unrelenting to sharpen the choice for Iran’s leaders to abandon their dangerous course,” says a joint statement issued by the Department of State and the Department of the Treasury. 

The following entities and individuals were added to the Treasury Department’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list:

1. Benham Shariyari 
2. Iran Air
3. Iran Air Tours
4. Mehr-E Eqtesad-E Iranian Investment Company
5. Tidewater Middle East Company

Poblete Tamargo expects global economic sanctions toward Iran, a state sponsor of terrorism under U.S. law, to increase in the foreseeable future. The U.S. Congress is also considering numerous new pieces of legislation and have been pressuring the Obama Administration to ratchet pressure on the Iranian through robust use of U.S. sanctions. 

For additional information, visit the OFAC website.