Iran Threat Reduction and Syria Human Rights Act of 2012 [Selected provisions]

Date issued: Aug. 10 2012

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TURBOFAC Commentary (753 words)

Notes on the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA)

1) The TRA, or ITRSHRA, is one of the six "self-containing," OFAC-administered pieces of Iran-related secondary sanctions legislation.[1]

The TRA substantially amends the ISA, CISADA and the Sec. 1245 of the FY 2012 NDAA. It also contains a substantial number of sanctions that were imposed by the TRA, are self-executing, and have not been further implemented by any regulation or EO, i.e. sections 211, 212, 213, 220, and 302.

Other TRA-imposed sanctions have been implemented by Sec. 7(a) of EO 13846. Sec....