The European Union, the United States, and other countries continue to impose new sanctions against Iran

Effective 6 February 2012, the President signed an Executive Order (“new EO”) imposing additional sanctions against Iran in order to implement section 1245 of the National Defense Authorization Act for Fiscal Year 2012 (NDAA), which was signed into law on 31 December 2011 (please see our 3 January 2012 Economic Sanctions Alert for more details about the NDAA). Under the new EO, all property and interests in property of the Government of Iran, including the Central Bank of Iran, and all Iranian financial institutions that are in the U.S., come within the U.S., or come within the possession or control of U.S. persons (including overseas branches) are blocked. Because of the pre-existing broad sanctions against Iran, the addition of a “blocking” requirement does not significantly impact U.S. companies. The new EO specifically affects U.S. financial institutions and their foreign branches, who are now required to “block” certain Iran-related payments that were previously required only to be “rejected.”

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