Emergency Contact NDAA 2013: A Potential Expansion Of U.S. Sanctions Against Iran As Of July 1, 2013 Home Latest updates Publications NDAA 2013: A Potential Expansion Of U.S. Sanctions Against Iran As Of July 1, 2013 15 Jul 2013 Download page as PDF Sign up for alerts This circular has been issued by the International Group of P&I Clubs and replaces circular 10/13 (13th June 2013). It should be read in conjunction with circular 09/13 (FAQs Regarding Enforcement against Foreign Persons of US Trade Sanctions against Iran). Amendments to circular 10/13 are highlighted in red. The National Defense Authorization Act for Fiscal Year 2013 (“NDAA 2013”) was enacted on January 2, 2013, and contains a subtitle, the “Iran Freedom and Counter-Proliferation Act of 2012” (“IFCA”), that sets out additional sanctions against foreign persons engaged in trade with Iran. IFCA takes effect on July 1, 2013, and has potentially far-reaching impact as it targets a wider range of activities than current sanction programs which are largely directed to Iran’s petroleum and petrochemical industries. To provide further clarification on how IFCA might be applied, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance on June 3, 2013, regarding the implementation of IFCA. Additionally, on June 3, 2013, President Obama signed an Executive Order (“E.O.”) which clarifies the types of penalties that can be imposed for violations of IFCA. Insofar as those involved in marine transportation and insurance are concerned, the more salient aspects of IFCA, as clarified by OFAC and the June 3, 2013 E.O., include the following. IFCA §1244: Transactions Involving Iran’s Energy, Shipping & Shipbuilding Sectors, Iranian Ports, or Iranians on the Specially Designed Nationals (“SDN”) List Transactions with Iran’s Energy, Shipping and Shipbuilding Sectors and its Ports Declaring that Iran’s “energy, shipping, and shipbuilding sectors” and its ports are facilitating Iran’s