NEWSLETTER-2019-metin

384 NEWSLETTER 2019 The US, through the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), employs economic sanctions pro- grams for a variety of purposes, including diplomatic, economic, and humanitarian purposes, as well as for national security matters. In this respect, the OFAC administers a complex sanctions regime against Iran. The Iran sanctions prohibit virtually all direct and indirect trans- actions involving Iran, the Government of Iran, persons who ordinar- ily reside in Iran, and entities that are located either in Iran, or formed under Iranian law, with a particular focus on the Iranian Revolutionary Guard Corps (IRGC). The OFAC operates in collaboration with the internal and exter- nal intelligence agencies of the US to develop its sanction programs. Other than the OFAC, there are a number of other US institutions that may be involved in certain sanctions, such as the US Department of Justice (DOJ) and the US Department of Commerce’s Bureau of In- dustry and Security (BIS). Within the scope of the sanctions regime, there are currently over 10 US statutes, over 20 executive orders issued by the President, as well as numerous regulations. Other than the IEEPA, there are also other important statutes that impose sanctions against Iran. These in- clude: • The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA); • The Comprehensive Iran Sanctions, Accountability, and Di- vestment Act of 2010 (CISADA); • The Iran Sanctions Act (ISA); • The Iran Freedom and Counter-Proliferation Act of 2012 (IFCA); • The Iran Threat Reduction and Syria Human Rights Act of 2012; • The National Defense Authorization Act of 2012 (NDAA); and