New Legislation Further Lengthens Reach of Extraterritorial Application of U.S. Embargo of Iran

In the wake of the June 9, 2010 adoption of United Nations Security Council Resolution 1929, on July 1, 2010, President Obama signed into law H.R. 2194, the “Comprehensive Iran Sanction, Accountability, and Divestment Act of 2010” (“CISADA”), which had been approved by both the U.S. House of Representatives and the U.S. Senate on June 24, 2010 by overwhelming majorities of 408 - 8 and 99 - 0, respectively. The legislation principally expands the scope of the Iran Sanctions Act (“ISA”) to more effectively target persons, including non-U.S. entities, engaged in activities relating to the Iranian petroleum sector.