|December 20, 2011|
Previously published on December 16, 2011
On December 15, 2011, the United States Congress approved the National Defense Authorization Act for Fiscal Year 2012 (H.R. 1540) (the “Act”), which contains, at Section 1245, new sanctions on Iran that potentially could bar a wide variety of non-U.S. financial institutions from access to the U.S. banking system. The legislation is expected to be signed by the President.