Making a List and Sanctioning it Twice*

Did you know that the State Department compiles a list of all the entities sanctioned under the Iran Nonproliferation Act? Well, now you do.

*Or five times, in the case of NORINCO.

Comments

[Michael Deal]

It will be interesting to see how this plays against foreign blocking legislation: Previously, there was some question as to whether the Iran Transactions Regulations (the principal embargo) or the Iran sanctions under the EAR were covered by the EUs decision to block ILSA, which are set forth in an appendix to the regulation (EU Regulation 96/2271), because Executive Order 12959 predated ILSA and ILSA does not explicitly refer to ITR although thee is a policy statement that appears to endorse them without calling them out by name. Now that the Executive Orders which the ITR implements are codified by an amendment to ILSA, the EU may be in a position where it is either legally obliged to block the sanctions against an EU person(including blocking cooperation with investigation of embargo violations by ICE/Customs and OEE) or formally waive application of its otherwise mandatory blocking regulations, which could have diplomatic repercussions especially in the Iran nuclear talks.