Targeting Foreign Evaders Of Iran And Syria Sanctions

Law360, New York (May 7, 2012, 1:56 PM EDT) -- On May 1, 2012, President Obama issued Executive Order 13608 — "Prohibiting Certain Transactions and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria" (Foreign Sanctions Evaders E.O.). This order authorizes the secretary of the treasury to prohibit a broad array of transactions involving foreign persons (foreign sanctions evaders) who have contravened existing U.S. sanctions against Iran and Syria, or have “facilitated deceptive transactions” with respect to such sanctions.

The Foreign Sanctions Evaders E.O. cites a series of prior...
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