New Iran Sanctions to Take Effect July 1

On July 1, 2013, a broad array of additional sanctions on non-US companies that engage in activities in Iran will take effect. The new sanctions were authorized under the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) (Subtitle D, §§ 1241-1255), which was enacted on January 2, 2013, as part of the National Defense Authorization Act for Fiscal Year 2013 (NDAA 2013), and under Executive Order 13645 (EO 13645), which was signed by the President on June 3. Together, IFCA and EO 13645 add an additional layer of penalties for non-US companies and financial institutions that provide support to Iran's energy, shipping, or port sectors; provide certain precious metals to Iran; provide insurance services for sanctionable activities; engage in transactions with certain Specially Designated Nationals (SDNs); or engage in transactions relating to goods or services used in Iran's automotive sector.