• President’s Order Prohibits Certain Sanction-Evasive Acts with Respect to Iran and Syria
  • May 4, 2012 | Authors: Gabriel Caballero; Andres A. Fernandez; Clemente L. Vázquez-Bello
  • Law Firm: Gunster - Miami Office
  • Yesterday, President Barack Obama issued an Executive Order (the “Order”) prohibiting certain transactions with and suspending entry into the U.S. of Foreign Sanctions Evaders (“FSEs”) with respect to Iran and Syria.

    The Order provides the U.S. Treasury Department (“Treasury”) with a new authority to further tighten the U.S. sanctions on Iran and Syria and targets foreign individuals and entities that have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions against Iran or Syria, or that have facilitated deceptive transactions for persons subject to U.S. sanctions concerning Syria or Iran.

    With this new authority, Treasury now has the capability to publicly identify foreign individuals and entities that have engaged in these evasive and deceptive activities, and generally bar access to the U.S. financial and commercial systems.

    The Order is the latest in a broad-based and escalating series of steps taken by the U.S. and its international partners targeting the governments of Iran and Syria with respect to their abuse of human rights, support for terrorism, and proliferation and development of weapons of mass destruction.

    As a result of the Order, financial institutions may need to enhance their current BSA/AML/OFAC programs to ensure compliance with the Order.