President Obama has signed an Executive Order expanding the U.S. Treasury Department’s authority to regulate the conduct of certain foreign entities even when they are not physically or financially present in the United States. The May 1 Order targets foreign entities that
(1) have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions against Iran or Syria;
(2) have facilitated deceptive transactions for persons subject to U.S. sanctions concerning Syria or Iran; OR
(3) are owned or controlled or are acting or purporting to act on behalf of an entity described in (1) or (2).
Treasury, in consultation with the State Department, may prohibit all transactions with designated entities, wherever they are located. The Order also prohibits providing to or receiving anything of benefit from a designated entity. The White House explained that the prohibitions aim to prevent the designated entities from having access to the U.S. market and financial system.
The Order does not designate specific entities.