Iran Sanctions: Navigating Through Vagueness

The U.S. Government recently took aggressive steps against shipping companies and others doing business with Iran. Those companies were sanctioned for, among other things, facilitating the development of petroleum resources and refined petroleum products by Iran under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA” or the “Act”). CISADA was enacted on July 1, 2010 to add to and amend the Iran Sanctions Act of 1996 (“ISA”). For much of its first year, CISADA went largely unenforced, but that changed on May 24, 2011, when the U.S. Government unleashed a wide array of sanctions on both foreign and U.S. companies, with a specific emphasis on the shipping business.

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