The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA) was signed by President Obama on 1 July 2010. The Act is particularly targeted at restricting Iran's ability to develop its domestic refined petroleum product (RPP) production ability and specifically bans the import of RPP to Iran, the import or provision of goods or services that could maintain or repair Iran's refineries or "facilitate" the development of the Iran's refining capability. CISADA also prohibits dealing with various named Iranian companies and individuals (Listed on the OFAC website). CISADA amends and expands the economic sanctions against Iran previously laid down in the U.S. Iran Sanctions Act of 1996. CISADA came into force on 1 July 2010.

The provisions of CISADA which may affect the Club and Members are complicated. The following only points to some of the relevant provisions of CISADA concerning Members and the Club:

In respect of PRODUCTION OF REFINED PETROLEUM PRODUCTS,

the President shall impose sanctions with respect to a person if the President determines that the person knowingly sells, leases, or provides to Iran goods, services, technology, information, or support

(i) any of which has a fair market value of $1,000,000 or more; or

(ii) that, during a 12-month period, have an aggregate fair market value of $5,000,000 or more.

"Goods, services, technology, information, or support" described in this paragraph are goods, services, technology, information, or support that could directly and significantly facilitate the maintenance or expansion of Iran's domestic production of refined petroleum products, including any direct and significant assistance with respect to the construction, modernization, or repair of petroleum refineries.

In respect of EXPORTATION OF REFINED PETROLEUM PRODUCTS TO IRAN,

the President shall impose sanctions with respect to a person if the President determines that the person knowingly

(i) sells or provides to Iran refined petroleum products

(I) that have a fair market value of $1,000,000 or more; or

(II) that, during a 12-month period, have an aggregate fair market value of $5,000,000 or more; or

(ii) sells, leases, or provides to Iran goods, services, technology, information, or support

(I) any of which has a fair market value of $1,000,000 or more; or

(II) that, during a 12-month period, have an aggregate fair market value of $5,000,000 or more.

"Goods, services, technology, information, or support" described in this paragraph are goods, services, technology, information, or support that could directly and significantly contribute to the enhancement of Iran's ability to import refined petroleum products, including;

(i) underwriting or entering into a contract to provide insurance or reinsurance for the sale, lease, or provision of such goods, services, technology, information, or support;

(ii) financing or brokering such sale, lease, or provision; or

(iii) providing ships or shipping services to deliver refined petroleum products to Iran.

The CISADA text is available among other resources provided in the website for the Office of Foreign Assets Control (OFAC) - a department of the US Treasury.

The following link accesses the Iran sanctions section of the OFAC website:

http://www.ustreas.gov/offices/enforcement/ofac/programs/iran/iran.shtml