Under Secretary for Terrorism and Financial Intelligence Stuart Levey testified yesterday before a Congressional committee on the implementation of economic sanctions on the Iranian regime. He said quite a bit during the hearing, but what was most of note were his comments on the recently enacted law, the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA).
CISADA is the 2.0 of the Iran Refined Petroleum Sanctions Act (IRPSA). It targets transactions dealing with Iran’s energy sector; and it has a lot more teeth than UN Security Council Resolution 1929 that was approved by the Security Council this past summer. It forces non-U.S. companies to make a choice between continuing to access the U.S. financial markets or go it alone with Iran and, of course, face possible prosecution in the U.S.
According to Levey, since June, the U.S. has discovered “43 entities in the banking, investment, mining, engineering, insurance, energy, petroleum, and petrochemical industries determined to be the Government of Iran” that have been listed on terrorist watch lists. Levey added that the U.S. has “contacted governments and financial institutions in more than a dozen countries to investigate conduct that could be sanctionable under the Act.”
Targeted economic sanctions laws and regulations such as CISADA will become the norm. It is likely that we will see more CISADA-like laws targeting institutions and individuals in other countries and regions of the world.
Levey’s prepared remarks are available, here.