E.O issued by U.S. President Obama on May 1, 2012, makes violating U.S. economic sanctions against Iran or Syria a basis for imposing sanctions against the responsible party. Whereas traditionally a violation of U.S. economic sanctions could result in a criminal or civil monetary penalty, now such violations can subject the responsible party to a range of sanctions, short of an asset freeze. The order also authorizes sanctions against a non-U.S. person who has “facilitated deceptive transactions for or on behalf of any person subject to U.S. sanctions concerning Iran or Syria.” OFAC announced that it “may use this authority where it appears that a foreign person violated U.S. sanctions on Iran or Syria but may not meet criteria for designation under existing Executive Orders.”

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