FACT SHEET: New Executive Order Targeting Foreign Sanctions Evaders

U.S. Department of the Treasury on May 1, 2012 released the following:

“WASHINGTON – Today the President signed an Executive Order (E.O.), “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria,” providing the U.S. Treasury Department with a new authority to tighten further the U.S. sanctions on Iran and Syria.

This E.O. targets foreign individuals and entities that have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions against Iran or Syria, or that have facilitated deceptive transactions for persons subject to U.S. sanctions concerning Syria or Iran. With this new authority, Treasury now has the capability to publicly identify foreign individuals and entities that have engaged in these evasive and deceptive activities, and generally bar access to the U.S. financial and commercial systems.

“The foreign sanctions evaders E.O. provides Treasury additional means to impose serious consequences on foreign persons who seek to evade our sanctions and undermine international efforts to bring pressure to bear on the Iranian and Syrian regimes. Whoever tries to evade our sanctions does so at the expense of the people of Syria and Iran, and they will be held accountable,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

Upon Treasury’s identification and listing of a foreign sanctions evader, U.S. persons will generally be prohibited from providing to, or procuring from, the sanctioned party goods, services, or technology, effectively cutting the evader off from the U.S. marketplace. This provides Treasury with a powerful new tool to prevent, deter, and respond to the risks posed by sanctions evaders to the U.S. and global financial system. It also will help prevent U.S. persons from unwittingly engaging in transactions with foreign individuals and entities that pose a particular risk of running afoul of U.S. sanctions concerning Iran or Syria.

The foreign sanctions evaders E.O. is the latest in a broad-based and escalating series of steps taken by the United States and its international partners targeting the governments of Iran and Syria with respect to their abuse of human rights, support for terrorism, and proliferation and development of weapons of mass destruction. The foreign sanctions evaders E.O. follows by one week the Executive Order Blocking The Property And Suspending Entry into the United States of Certain Persons with Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology (the “GHRAVITY E.O.”), which targeted the provision and use of information and communications technology to facilitate computer or network disruption, monitoring, or tracking that could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria.

The United States has already blocked (i.e., frozen) property and interests in property of the Government of Iran, its agencies and instrumentalities, and all Iranian financial institutions, including the Central Bank of Iran. In all, the Treasury Department has announced over 400 Iran-related designations and identifications of individuals and entities supporting various illicit actions of the Government of Iran, including human rights abuses, support for terrorism, and WMD proliferation. For more information, please see http://www.treasury.gov/ofac.

Similarly, the Administration has blocked the property and interests in property of the Government of Syria and its agencies and instrumentalities, including the Central Bank of Syria. The Treasury Department also has designated major Syrian financial institutions, including the Commercial Bank of Syria. In all, the Treasury Department has designated more than 60 individuals and entities supporting Syria’s human rights abuses and other repressive policies. For more information, please see http://www.treasury.gov/ofac.”


Douglas McNabb – McNabb Associates, P.C.’s
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Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


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