Furthermore, congressionally-mandated investigations and sanctions impinge on executive discretion. The Obama Administration was unenthusiastic at best regarding CISADA, as CISADA's unilateral, extraterritorial sanctions run counter to the Obama Administration's goals of seeking multilateral sanctions. entity engaged in sanctionable activity, the State Department is required to impose at least three of nine sanctions, which range in severity, from a statutory list. If the State Department finds the non-U.S. entities that engaged in activity that supported Iran's ability to refine or import refined petroleum products. One of the major effects of CISADA was an expansion of the Iran Sanctions Act to require the State Department to investigate non-U.S. In July 2010, Congress passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). This alert summarizes the impact of these designations from both a legal and practical risk-management perspective.

These sanctions represent a marked increase in the State Department's enforcement of the Act, which was expanded in 2010 to target companies in the maritime industry that provide goods or services that assist Iran in obtaining refined petroleum products. State Department imposed sanctions on seven companies under the Iran Sanctions Act.

Ofac iran sanctions act