On December 26, 2012, the US Treasury Department's Office of Foreign Assets Control (OFAC) issued a final rule amending its Iranian Transactions and Sanctions Regulations (ITSR) to prohibit certain transactions between non-US entities and Iranian interests. Among other things, these amendments implement an executive order issued by President Obama on October 9, 2012.

As dictated by the executive order, the amendment prohibits non-US entities owned or controlled by a US person from knowingly engaging in any transactions, directly or indirectly with the government of Iran or any person subject to its jurisdiction (prohibited transactions). It also authorizes, from October 9, 2012 to March 8, 2013, all transactions ordinarily incident and necessary to the winding down of prohibited transactions, provided that the authorized transactions do not involve a US person or occur in the US.

For more information on the executive order from October 9, 2012, see Legal Update, Executive Order Prohibits US Company Subsidiaries from Engaging in Transactions with Iran.