On October 9, 2012, President Obama issued an Executive Order implementing certain provisions of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”). The Order authorizes the Secretary of State and Secretary of the US Treasury to apply sanctions against non US persons and US companies for the acts of foreign subsidiaries who engage, or have engaged, in transactions related to Iran’s oil & gas sector or its alleged attempts to develop weapons of mass destruction. The Order is the latest in a series of actions by the Obama administration and the US Congress designed to apply pressure on Iran through sanctions against non US persons who transact with Iran.View full memo, "President Obama Issues Executive Order Authorizing Imposition of Sanctions on Non-US Persons Who Transact with Iran"
