On July 1, 2010 President Obama signed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (the “Act”) into law. The Act, which is discussed in the attached memo, broadens both the activities that may lead to sanctions on foreign persons who deal with the Iranian petroleum sector (particularly for those providing indirect services such as financing, shipping, or insurance) and the potential severity of those sanctions, although it maintains the basic structure of the prior law pursuant to which most sanctions are not automatic but require further action by the executive branch. The Act also tightens sanctions on Iran in a number of other ways, including by restricting dealings with financial institutions seen as supporting the Iranian regime and providing penalties for the sale of certain telecommunications equipment to Iran.
