January 2012

Actions to Enforce the Iran Sanctions Act and Implement Contractor Certification Requirement

The paper discusses efforts to enforce the US Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010. The act expanded existing sanctions to include firms aiding Iran’s development of refined petroleum products. The sanctions exclude such firms from receiving US government contracts. Firms seeking US government contracts must certify that they are not engaged in activities which would contravene the sanctions. Firstly, this report identifies State actions and processes to enforce energy sector-related sanctions. Secondly, it describes the implementation of the contractor certification requirement and identifies any indications of false certifications or the need for waivers of the certification requirements.

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