Iran Sanctions Legislation Pending in the US Congress
Economic Sanctions Insight discusses the current status of the bills constituting the proposed legislation: HR 2194 - Iran Refined Petroleum Sanctions Act of 2009 (IRPSA), passed by the House of Representatives, and S 2799 - Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2009, passed by the Senate. The summary also discusses the legislation in the context of the Obama Administration’s efforts to forge consensus on multilateral sanctions against Iran, and the implications of the legislation if enacted into law. On March 11, 2010, the Senate passed HR 2194 with amendments incorporating the additional sanctions contained within the original Senate bill of S 2799. A conference committee will reconcile HR 2194 with the version of HR 2194 passed by the Senate.
If enacted into law in their current state, the pending legislation would amend the existing Iran Sanctions Act of 1996, and at a minimum, require the imposition of sanctions against, amongst others, foreign (non-US) entities that sell refined petroleum to Iran; provide shipping, insurance, reinsurance or other services for the delivery of refined petroleum to Iran; or supply equipment to or construct oil facilities in Iran.
Mr. Eren and Mr. Pinter of The Eren Law Firm served at the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the US government agency that administers and enforces US economic sanctions, for a combined 25 years prior to entering private law practice, respectively 7 and 9 years ago. While at OFAC, Mr. Eren and Mr. Pinter, in addition to their other responsibilities at OFAC, participated in deliberations with respect to sanctions-triggering activity under the Iran Sanctions Act, including investments in Iran by Total, Gazprom, and Petronas. Mr. Eren and Mr. Pinter advise and represent a variety of clients on all aspects of economic sanctions administered by OFAC (sanctions practice brochure).