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Focus on Regulation

Iran: New Developments and Additional Sanctions

The United States and European Union have continued to impose or propose additional sanctions and restrictive measures targeting certain dealings with Iran or with designated persons and entities. These developments include: (1) a recent decision by the Council of the European Union (EU) to require financial messaging providers to discontinue communication services to certain Iranian financial institutions, which effectively cuts off those Iranian banks from accessing international funds transfers, (2) the new EU Council Regulation, which implements various Iran sanctions measures from 2012 and makes substantive changes to existing provisions, (3) a recent temporary exemption by the U.S. State Department of eleven countries from the Iran sanctions under the National Defense Authorization Act of 2012 (NDAA), which will enable financial institutions from those countries to process certain Iran-related transactions (during a 6-month period) without exposing themselves to possible restrictive measures under the NDAA, (4) the issuance of the revised Iranian Financial Sanctions Regulations implementing the provisions of the NDAA targeting certain dealings by non-U.S. financial institutions with the Central Bank of Iran (CBI) and designated Iranian financial institutions, and (5) several bills pending in the U.S. Congress that would further expand sanctions against Iran.  For additional information related to these recent developments, please see the Hogan Lovells Economic Sanctions Alert on Iran Sanctions Developments, dated 29 March 2012.