The National Defense Authorization Act of 2013 (NDAA), dated January 2nd of this year, includes the Iran Freedom and Counter-Proliferation Act (IFCA) in its Subtitle D. It's bigger than a breadbox (yes, Mr. Watchlist will write a post or two explaining it), so here are just the section listings of note:
Sense of Congress relating to violations of human rights by Iran.Imposition of sanctions with respect to the energy, shipping, and ship-building sectors of Iran.
Imposition of sanctions with respect to the sale, supply, or transfer of certain materials to or from Iran.
Imposition of sanctions with respect to the provision of underwriting services or insurance or reinsurance for activities or persons with re-spect to which sanctions have been imposed.
Imposition of sanctions with respect to foreign financial institutions thatfacilitate financial transactions on behalf of specially designated nationals.
Impositions of sanctions with respect to the Islamic Republic of IranBroadcasting.
Imposition of sanctions with respect to persons engaged in the diversionof goods intended for the people of Iran.
Waiver requirement related to exceptional circumstances preventing significant reductions in crude oil purchases.
Statute of limitations for civil actions regarding terrorist acts.
Report on use of certain Iranian seaports by foreign vessels and use of foreign airports by sanctioned Iranian air carriers.Implementation; penalties.
Applicability to certain natural gas projects.
The President today signed an Executive Order authorizing some of the sanctions in the IFCA as well as additional sanctions on Iran. These additional sanctions accomplish 3 things:
- material support for Iran's automotive sector can be sanctioned
- prohibit dealing in Iran's currency (the rial)
- allow the sanctioning of persons who aid people sanctioned under various Iranian sanctions programs
OFAC has published a frequently-asked questions page for today's action, due to its length and complexity. It's one of those documents that we compliance types live for.
Watch this space for more detail on the IFCA and today's EO.