US Imposes New Sanctions on Iran, Including Central Bank

February 7, 2012

On February 5, 2012, President Obama issued Executive Order 13599, effective February 6, 2012, placing further sanctions on the Government of Iran and Iranian financial institutions, including implementing section 1245 of the National Defense Authorization Act. The President noted that the increased sanctions were being imposed “in light of the deceptive practices of the Central Bank of Iran and other Iranian banks to conceal transitions of sanctioned parties, the deficiencies in Iran’s anti-money laundering regime and the weaknesses in its implementation, and the continuing and unacceptable risk posed to the international financial system by Iran’s activities”. The Executive Order blocks all property and interests in property of the Government of Iran and Iranian financial institutions, including the Central Bank of Iran, that are in the United States, that come within the United States, or that are in or come within the possession or control of any United States person, including any foreign branch. Such property and interests in property may not be transferred, paid, exported, withdrawn or otherwise dealt in. According to the U.S. Department of the Treasury, U.S. persons were previously required to “reject” rather than “block” (i.e. freeze) Iranian transactions.  The Treasury is, however, issuing general licenses to maintain existing authorizations for certain transactions that advance U.S. foreign policy interests.

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