On 31 July 2012, President Obama signed an Executive Order Authorizing Additional Sanctions With Respect to Iran. This Order:
(a) authorizes the Secretary of the Treasury to impose financial sanctions on foreign financial institutions found to have knowingly conducted or facilitated certain significant financial transactions with the National Iranian Oil Company (“NIOC”) or Naftiran Intertrade Company (“NICO”) or for the purchase or acquisition of petroleum or petroleum products from Iran through any channel;
(b) provides the Treasury with new authority to impose sanctions on foreign financial institutions found to have knowingly conducted or facilitated significant transactions for the purchase or acquisition of petrochemical products from Iran; and
(c) provides authority for the Treasury to block the property and interests in property of any person determined to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, NICO or the Central Bank of Iran, or the purchase or acquisition of US bank notes or precious metals by the Government of Iran.
The Order also adds to the State Department’s existing authorities under the Iran Sanctions Act and Executive Order 13590, now sanctioning buyers of Iranian petroleum and petrochemicals.
The Treasury also announced sanctions under the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (“CISADA”) against two financial institutions (the Bank of Kunlun in China and Elaf Islamic Bank in Iraq) for knowingly facilitating significant transactions or providing significant financial services for designated Iranian banks. These banks are now effectively cut off from the US financial system.
The full text of the Executive Order can be found on the US Treasury website.