The final quarter of 2012 was marked by US and EU efforts to prevent Iran from circumventing existing sanctions, an increasingly extraterritorial bent to US sanctions, and record breaking sanctions-related settlements by foreign financial institutions with US authorities. In the US, the Obama administration worked to implement the numerous provisions of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Threat Reduction Act”), signed into law in August of last year, while Congress passed legislation imposing even more expansive sanctions targeting Iran that will go into effect later in 2013. The US and EU also continued to designate new individuals and entities in Iran and Syria as the targets of sanctions for their involvement in human rights abuses, terrorist activities, and the proliferation of weapons of mass destruction. Finally, while US sanctions targeting Sudan, Cuba, and the old Gaddafi regime in Libya remain in place, the US took action to suspend sanctions targeting Myanmar (Burma) in response to its ongoing efforts at democratic reform, demonstrating that sanctions are not always a one-way ratchet.
View full memo, "Sanctions Round-Up: Fourth Quarter 2012"