The Partial Lifting of Iranian Sanctions Not Quite Business As Usual – January 21, 2016

Womble Carlyle Sandridge & Rice

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__________________ Womble Carlyle client alerts are intended to provide general information about significant legal developments and should not be construed as legal advice regarding any specific facts and circumstances, nor should they be construed as advertisements for legal services. i Executive Order 12613 Executive Order 12957 iii Executive Order 12959 iv Executive Order 13059 v In November 2008, authorization for “U-turn” transfers involving Iran was revoked, barring US banks from processing any transfers involving Iran that originated and ended with non-Iranian foreign banks. In September 2010, the US Congress enacted the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) thereby revoking authorization to import into the United States certain foodstuffs and carpets of Iranian origin. In August 2012, President Obama signed the Iran Threat Reduction and Syria Human Rights Act (“ITRA”) which, in combination with the Iran Sanctions Act of 1996 and CISADA, tightened sanctions on Iran even further. vi Executive Order 13628 ii 6 .