Iran sanctions developments

Over the past several weeks, the United States and European Union have continued to impose additional sanctions, have taken steps to implement previously imposed restrictive measures, and/or have proposed new sanctions targeting certain dealings with Iran and/or designated persons and entities. These developments include: (1) a recent decision by the Council of the European Union (EU) to require financial messaging providers to discontinue communication services to certain Iranian financial institutions, (2) the new EU Council Regulation, which implements various Iran sanctions measures from 2012 and makes substantive changes to existing provisions, (3) a recent temporary exemption by the U.S. State Department of eleven countries from the Iran sanctions under the National Defense Authorization Act of 2012 (NDAA), (4) the issuance of the revised Iranian Financial Sanctions Regulations implementing the provisions of the NDAA targeting certain dealings by non-U.S. financial institutions with the Central Bank of Iran (CBI) and designated Iranian financial institutions, and (5) several bills pending in the U.S. Congress that would further expand sanctions against Iran. Brief summaries of these recent developments are included below.

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