Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) [Selected Provisions]

Date issued: Jan. 02 2013

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TURBOFAC Commentary (766 words)

Notes on the Iran Freedom and Counter-Proliferation Act of 2012

1) The Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) is one of the six "self-containing," OFAC-administered pieces of Iran-related secondary sanctions legislation. [1]

2) The sanctions imposed by IFCA have a complex relationship both with the TRA, ISA and CISADA sanctions imposed prior to the passage of IFCA, as well as with Executive Order 13846 of August 6, 2018 (Reimposing Certain Sanctions With Respect to Iran), which implements some (but not all) IFCA sanctions while invoking standard IEEPA authorities to impose sanctions that overlap in scope with IFCA sanctions but operate independent of them. On that issue...