International Trade and Customs

Contact: Jahna M. Hartwig; Williams Mullen (North Carolina & Virginia, USA)

On October 9, 2012, the President signed an Executive Order ¹ to Implement the Iran Threat Reduction and Syria Human Rights Act of 2012.² Section 4 of the Order prohibits entities that are owned or controlled by U.S. persons from “knowingly engag[ing] in any transaction, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran” if U.S persons would be prohibited from engaging in the transaction under the Iran sanctions regulations³ administered by the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department. Please click here to continue reading.

¹See Executive Order from the President regarding Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions with respect to Iran (available at http://www.whitehouse.gov/the-press-office/2012/10/09/executive-order-president-regarding-authorizing-implementation-certain-s).
²Pub. L. 112-158 (Aug. 10, 2012).
³See 31 C.F.R. Part 560.