The President has issued a new Executive Order that effectively expands the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) to cover activities in the Iranian petrochemical sector and tightens the existing definitions of sanctionable investment in Iranian oil and gas production. Simultaneously, the Treasury Department designated Iran as a jurisdiction of primary money laundering concern under the Patriot Act. While this designation does not have a significant direct impact given the existing comprehensive sanctions prohibiting the processing of Iran-related transactions through the United States, it serves as a warning to foreign financial institutions that any dealings with Iranian banks will be subject to intensified scrutiny and possible future consequences.
