Recent Sanctions Developments: Iran, Syria, and Burma

Recent sanctions developments with respect to Iran and Syria, targeting non-U.S. persons who provide censorship and monitoring equipment to those countries or help conceal their participation in transactions, continue the growing trend of extraterritorial efforts aimed at persons who are acting outside the reach of U.S. sanctions. The new sanctions programs threaten that non-U.S. persons engaged in such transactions could themselves become the target of U.S. sanctions, even if dealing completely outside of the United States in a foreign currency. Meanwhile, despite extensive publicity surrounding positive political developments in Burma and the easing of sanctions by other countries, the pace of future change with respect to U.S. sanctions there remains unclear, with only modest steps toward liberalization to date.

The attached memorandum includes more detail on these recent developments.