On July 1, 2010, President Obama signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). This law builds upon UNSCR 1929 by strengthening existing U.S. sanctions with respect to the Iranian energy industry, and adds the potential for the imposition of serious limits on foreign financial institutions’ access to the U.S. financial system if they engage in certain transactions involving Iran. CISADA is consistent with the global consensus regarding Iranian behavior and is in line with the U.S. Government’s core role of protecting its domestic financial system from exposure to Iran’s illicit and deceptive financial practices.
The Treasury Department only administers Sections 103, 104, and 105 of CISADA. Other aspects of the legislation are implemented and/or administered by other agencies. Of note, the amendments to the Iran Sanctions Act concerning energy investment and refined petroleum activities are implemented by the State Department.