On August 10, 2012, President Obama signed into law the Iran Threat Reduction and Syria Human Rights Act of 2012 (the "Act"). The passage of the Act, which reflects the strengthening of a comprehensive US Government approach to intensify sanctions against Iran, follows the recent issuance of several Executive Orders that broaden the extraterritorial application of US sanctions against foreign financial institutions ("FFIs") and non-US entities generally, principally in connection with Iran's energy and banking sectors, as well as parties designated under the Weapons of Mass Destruction or Terrorism sanctions programs. The Act further expands the scope and coverage of these types of measures.
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