• New US Sanctions in FY 2013 National Defense Authorization Act Expand on Trend to Apply Pressure on Third Country Business with Iran
  • January 28, 2013 | Authors: Adam M. Brenner; Maria R. Cirincione; Mario Mancuso; John Pisa-Relli
  • Law Firms: Fried, Frank, Harris, Shriver & Jacobson LLP - New York Office ; Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office
  • On January 2, 2013, President Obama signed a law significantly expanding existing US economic sanctions against Iran and targeting non-US third parties that do business with Iran. The Iran Freedom and Counter-Proliferation Act of 2012 (the "IFCPA"), codified at Subtitle D, §§ 1241-1255 of the National Defense Authorization Act for Fiscal Year 2013 (H.R. 4310) (the "2013 NDAA"), overwhelmingly passed the House and Senate in late December 2012. This memorandum examines the US government's continued reliance on such extraterritorial sanctions and summarizes key provisions of the IFCPA, as well as potential implications these new sanctions measures hold for multinational companies.