comprehensive iran sanctions accountability and divestment act of 2010 pdf

Comprehensive iran sanctions accountability and divestment act of 2010 pdf

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2011 Report to the Congress: Comprehensive Iran Sanctions Accountability and Divestment Act of 2010

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U.S. Department of State

In case of emergency, Members and Correspondents are encouraged to contact the Claims Team direct whenever possible.

Be sure to leave feedback using the 'Feedback' button on the bottom right of each page! The Public Inspection page on FederalRegister. The Public Inspection page may also include documents scheduled for later issues, at the request of the issuing agency. The President of the United States manages the operations of the Executive branch of Government through Executive orders. The President of the United States communicates information on holidays, commemorations, special observances, trade, and policy through Proclamations.

2011 Report to the Congress: Comprehensive Iran Sanctions Accountability and Divestment Act of 2010

Download file as PDF. His focus, as part of the State Department, is on the energy sector, as opposed to the finance sector, which falls within the remit of the US Treasury. Some of the guests preferred to remain anonymous while others were happy to disclose their identities and exchanged details with the US Government officials. Mr Delare stressed from the outset that the US Government wants to engage constructively with the international business community on the implementation of Iran Sanctions and that he expected that the feedback from a meeting such as this would be very helpful to them in understanding the concerns of business people. He also mentioned the fact that he is an economist by training rather than a lawyer and will need to refer certain issues to the State Department lawyers. He oversees CISADA but does not regard himself as an expert in the relevant industries and he was therefore seeking to gain a better understanding of how these industries work.

First, I have approved a new Executive order that imposes new sanctions against the Iranian energy and petrochemical sectors. This action is designed to deter Iran from establishing payment mechanisms for the purchase of Iranian oil to circumvent existing sanctions and utilizes the existing structure of our sanctions law, including exceptions for significant reductions in the purchase of Iranian oil. Additionally, existing sanctions on Iran's petrochemical industry are expanded by making sanctionable the purchase or acquisition of Iranian petrochemical products. Sanctions are also authorized for those who may seek to avoid the impact of these sanctions, including against individuals and entities that provide material support to the National Iranian Oil Company, Naftiran Intertrade Company, or the Central Bank of Iran or for the purchase or acquisition of U. Second, we have also taken a significant step to hold responsible institutions that knowingly enable financial transactions for designated Iranian banks. Bank of Kunlun and Elaf Islamic Bank have facilitated transactions worth millions of dollars on behalf of Iranian banks that are subject to sanctions for their links to Iran's illicit proliferation activities.

Nevertheless licence holders are encouraged to take them in consideration when conducting their business activities. It is understood that under CISADA, the US Treasury may require US banks to request specified non-US banks for whom they maintain correspondent accounts, to certify whether they maintain correspondent accounts in any currency with Iranian-linked financial institutions designated by OFAC or whether they have processed fund transfers in any currency related to any financial institution or any person or entity designated by OFAC, even if such fund transfers do not involve US correspondent accounts. Furthermore a US bank, on the basis of the information received, may decide to terminate its correspondent relationship or file a suspicious activity report in accordance with its anti-money laundering and sanctions compliance obligations. Sanctions include directing US banks to terminate US correspondent banking relations with such non US banks, blocking their access to the US financial system. Financial services licence holders, particularly credit institutions, are therefore strongly advised to consider carefully the provisions of CISADA, which although not directly binding, may have serious implications on their business activities. This notice is being published for information purposes only. It does not contain or purport to contain a complete description or analysis of the provisions of CISADA or any form of advice thereon.

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Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy. As discussed below, non-U. Taken together, these provisions have the potential to represent the most significant extraterritorial expansion of U. Because U. Although the ISA provides the President broad authority to impose these sanctions on persons he deems to be in violation of the ISA, the United States has never pursued sanctions under the ISA, instead preferring to work with other nations to encourage companies to cease activities in Iran voluntarily. As a result, no person has been sanctioned under the ISA to date.

At their meeting on 12th July , the Directors considered the implications for the Association of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of , which was enacted in the United States on 1st July. In this connection, underwriting or entering into a contract providing insurance or reinsurance for the provision of such goods or services, as well as providing ships or shipping services to deliver RPP to Iran are specifically identified as sanctionable activities. RPP is defined as "diesel, gasoline, jet fuel including naphtha-type and kerosene-type jet fuel and aviation gasoline". The relevant section Section 5 a 3 B of the Iran Sanctions Act, as amended reads: "Goods, services, technology, information, or support described in this subparagraph are goods, services, technology, information, or support that could directly and significantly contribute to the enhancement of Iran's ability to import refined petroleum products, including - i except as provided in subparagraph C , underwriting or entering into a contract to provide insurance or reinsurance for the sale, lease, or provision of such goods, services, technology, information or support; ii financing or brokering such sale, lease, or provision; or iii providing ships or shipping services to deliver refined petroleum products to Iran. The Board reviewed the terms of Rule 5 J ii , which was introduced for the policy year and reads as follows:. The Board considered that the risk of the Association being or becoming subject to a sanction under the CISADA legislation was a material risk in the context of this Rule and that any such sanction would have a material effect on the Association. Although any such case will be considered by the Directors on its individual circumstances, the Board wishes to draw the attention of Members to the power the Directors have under this Rule to terminate the insurance of a Member in respect of any ships where the Member has exposed or will expose the Club to a material risk of sanction under the terms of CISADA


In its broad extraterritorial application, the Act provides strong disincentives to firms that provide energy-related services, insurance and reinsurance services, and shipping services to Iran. It targets not just the firms themselves, but also their corporate officers and principals by restricting their access to the United States and permitting the imposition of other sanctions against them in their individual capacities. Companies should monitor ongoing implementation of the new legislation, review its potential impact, and establish effective due diligence and compliance programs that address their conduct in the United States and abroad. This legislative action targeting Iran complements increasingly strong executive action. It also authorized sanctions against those who provide material support to major entities in the Iranian energy sector or the Central Bank of Iran for the purchase or acquisition of US bank notes or precious metals by the Government of Iran.

U.S. Department of State

Congress that applies further sanctions on the government of Iran. This increased pressure is part of the larger campaign over the Iranian nuclear program , and aims to target Iranian dependence on imports for its gasoline needs. Despite the reliance on foreign suppliers, the Gas Rationing Plan did lead to a decline in imports. The idea of reducing Iranian gasoline imports as a means of pressuring Iran was examined during the administration of President George W. Bush but ultimately not taken up. During the presidential campaign , then candidate Barack Obama brought up the idea in a presidential debate.

CISADA expands significantly the energy-related activities that are sanctionable and adds new types of sanctions that can be imposed. The United States is resolved to make full use of ISA and the other authorities in CISADA as additional tools in our efforts to convince the Iranian Government to change its strategic calculus, comply with its full range of nuclear obligations, and engage in constructive negotiations on the future of its nuclear program. Activities that can trigger sanctions include:. Sanction Provisions Three or more out of nine possible sanctions shall be imposed on any person determined to have engaged in sanctionable activities. The nine sanctions would prohibit:. Waivers ISA does provide for certain waivers. These waivers may be applied on a case-by-case basis with respect to a sanctionable person depending on the facts and U.

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Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010


  • Lowell G. 21.04.2021 at 07:15

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