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Legal Briefing
An overview of the Obama Administration's new sanctions against Iran
Practice Area: Cross-border: Commercial and International Trade
Sector: Business services
Jurisdiction: USA
Published: 06 December 2011
Law Firm: Bingham McCutchen
Overview
On 21 November 2011, the Obama administration announced that it would impose new sanctions against Iran, directed at its financial, petroleum and petrochemical sectors.
The US Secretary of Treasury has announced that there are reasonable grounds to conclude that Iran is a "jurisdiction of primary money laundering concern" under the USA PATRIOT Act. Based on this finding, the Financial Crimes Enforcement Network has issued a notice of proposed rule making that will potentially lead to sanctions against financial institutions doing business directly or indirectly with any financial institutions in the Iranian banking sector. With respect to the petroleum and petrochemical sectors, the new sanctions target entities and persons supplying goods and services to these sectors in amounts exceeding certain thresholds.
In this briefing, Bingham McCutchen outline the sanctions' background and looks in detail at how they will affect each of the aforementioned Iranian sectors.
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