New Executive Order Targets Iran And Syria "Foreign Sanctions Evaders"

On May 1, 2012, the US Treasury Department's Office of Foreign Assets Control ("OFAC") announced a new Executive Order¹ ("the EO") that broadens the scope of US sanctions against Iran and Syria to prohibit certain transactions with "foreign sanctions evaders."

This expansion of US restrictions on Iran and Syria comes amid a broader push by the US to enhance economic pressure on those countries and further isolate them from international markets. US law has long prohibited most direct commercial relationships between the US and Iran, and imposed heavy restrictions on a wide range of commerce between the US and Syria. Accordingly, the main thrust of recent developments in US sanctions concerning Iran and Syria is to prevent third parties from providing Iran and Syria with goods, services, or technology. As a general matter, US sanctions seek to force third parties to choose between doing business with the US (and the rest of the world) or doing business with Iran or