Amendment to the Iranian Financial Sanctions Regulations: Implementing subsection 1245(d) of the National Defense Authorization Act for Fiscal Year 2012 ('NDAA')

On February 27, 2012, the Office of Foreign Assets Control amended the Iranian Financial Sanctions Regulations, 31 C.F.R. part 561 (the "IFSR"), and republished them in their entirety, to implement subsection 1245(d) of the National Defense Authorization Act for Fiscal Year 2012 ("NDAA"). The amended IFSR provide for sanctions on foreign financial institutions that knowingly conduct or facilitate certain significant financial transactions with the Central Bank of Iran or a U.S.-designated Iranian financial institution. In addition, the amended IFSR contain various time-based triggers for the imposition of sanctions, beginning February 29, 2012, subject to certain exceptions authorized by the NDAA.