Effective January 23, 2012, the European Union (EU) implemented significantly expanded sanctions against Iran. Adopted by Council Decision 2012/35/CFSP, Council Regulation (EU) No. 56/2012, and Council Implementing Regulation (EU) No. 54/2012, the new measures: (1) ban imports of Iranian petroleum resource-related products; (2) take additional actions against energy, financial, and transport sectors dealing with and providing assistance to Iran’s petroleum resource-related sector; (3) prohibit c