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Since amending the Iran Sanctions Act (“ISA”) by passage of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”), the U.S. Congress has continued its efforts to isolate Iran by expanding both the scope of sanctionable activity and the types of sanctions that can be meted out by the U.S. Government. As with CISADA, many of the pending bills have particular focus on or consequences for the maritime industry and extend to both U.S. and non-U.S. persons
During the past six months, U.S. efforts to build global support for sanctions against Iran have resulted in a major sea change for the international shipping community and other industries doing business with Iran, and the wave of sanctions activity continues to build despite indications that the cumulative effect of the new embargoes has begun to achieve the desired impact
