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Amendment to S2101

Amendment to S2101

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Published by Josh Rogin

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Published by: Josh Rogin on Mar 27, 2012
Copyright:Attribution Non-commercial


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Amendment to S. 2101
Section by Section Analysis
Background: No Good Ideas Left Behind
As Iran continues inching closer to “red lines” su
rrounding its illicit nuclear weapons program,S. 2101 will likely serve as the last legislative vehicle to impose further economic sanctionsagainst the Islamic Republic until December. Therefore, as long as opportunities exist toincorporate new ideas and creative sanctions into the legislation, we should seize upon thoseopportunities in overwhelming bipartisan fashion. In this way, we keep our promise to the
American people and support the President’s stated objective to exhaust every available
diplomatic option.
Section 1: Defining Credible Information to Include GAO and CRS Reports
 The Iran, North Korea, and Syria Sanctions Consolidation Act of 2011 (S. 1048), of which morethan 80 Senators are cosponsors, sought to amend the Iran Sanctions Act to force theAdministration to open an investigation into any entity reported by the GovernmentAccountability Office (GAO), the Energy Information Administration (EIA), the CongressionalResearch Service (CRS) or a similarly credible governmental agency to have violated U.S.sanctions. S. 2101 removed this amendment, instead leaving it up to the President to use his
discretion as to whether such reports should be deemed “credible” or not.
 This amendment to S. 2101 would revert to the language supported by more than 80 U.S.
Senators (i.e. defining “credible information” to include GAO, CRS, EIA and similar 
government reports).
Amends Section 204 of S. 2101 to ensure that the “credible information” needed to
initiate an investigation under the Iran Sanctions Act includes GAO, CRS, EIA and similargovernment reports.
Section 2: Sanctions Against Service Providers to Iranian Financial Institutions
 The amendment seeks to expand sanctions already included in the underlying legislationtargeting secure financial communications providers like the Society for Worldwide Interbank 
Financial Telecommunication (commonly known as “SWIFT”).
 Requires the Secretary of the Treasury to submit a report within 90 days on the status of efforts to ensure that SWIFT, Clearstream, and other entities that provide similar services,have terminated the provision of services to, and the enabling and facilitation of access toservices for, the Central Bank of Iran and other Iranian financial institutions.After 90 days, if such service providers have not terminated the provision of services tothe CBI or other Iranian financial institutions, authorizes the President to impose sanctionsagainst the entity or its directors.Requires such service providers to disclose to the Treasury Department any Iranian assetsunder their management and any services offered to clients holding Iranian assets.
In this case, the term “services” includes communications, financial
(including trade andpost-trade), hardware, software, or professional consulting services.
Section 3: Expansion of CISADA Financial Sanctions
Section 1245(b) of the FY12 National Defense Authorization Act (“Menendez
Kirk”) designated
the financial sector of Iran as a primary money laundering concern because of the threat togovernment and financial institutions resulting from the illicit activities of the Government of Iran, including its pursuit of nuclear weapons, support for international terrorism, and efforts todeceive responsible financial institutions and evade sanctions. This amendment aligns currentfinancial sanctions against Iran with this designation by expanding CISADA sanctions to includeall Iranian financial institutions.Amends CISADA to prohibit U.S. financial institutions from maintaining correspondentaccounts with international financial institutions that maintain correspondent accounts withany Iranian financial institution. Currently, CISADA only extends this prohibition for
“designated” Iranian financial institutions.
 On the suspicion that international financial institutions are concealing sanctionableactivity, requires international financial institutions that maintain correspondent accounts inthe United States to biannually disclose to the Treasury Department its dealings with Iranianfinancial institutions.
Failure to disclose forfeits the institution’s privilege of maintaining
correspondent accounts in the United States. The Treasury Department is required to postsuch disclosures online with 72 hours of receipt.
Section 4: Expansion of “Menendez
Kirk” CBI Sanctions
 This amendment seeks to expand the financial sanctions contained in Section 1245 of the FY12National Defense Authorization Act.Imposes sanctions on international financial institutions that conduct significanttransactions with Iranian financial institutions.Expands sanctions regarding non-oil transactions to cover government-ownedinternational financial institutions.

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