While he was no doubt using the platform in New York to speak to a domestic audience and energize hardliners back home, the reality is that around the world a number of governments are (finally) waking up and taking action to impose meaningful sanctions against Iran. In the past three months, the United States, Canada, the European Union, Australia, Japan, and South Korea have all enacted comprehensive new sanction laws targeting Iran.

With respect to the new U.S. law, September 29th was significant because it marked the day that the most biting of U.S. sanctions, covering a wide-range of energy, telecommunications, and financial sectors, took effect. From this point forward, any company bidding on contracts with the U.S. government, the largest business in the world, must certify that they do not also engage in business covered under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 signed into law by President Obama this past July.

These new changes are long overdue. Consider that the Government Accountability Office, the watchdog of the U.S. government, found that close to $900 million in federal funds went to companies doing business in Iran's energy sector in the past five years. Iran's energy sector is largely controlled by the Iran Revolutionary Guard Corps, the government and military unit in charge of Iran's nuclear program and designated by the U.S. State Department as a terrorist organization. Put differently, American tax dollars had been supporting Tehran's efforts to develop a nuclear weapon, sponsor terrorism, and engage in brutal crackdowns against its own people.


The new law also closes a significant loophole found in previous U.S. sanction provisions by covering not only U.S. companies and financial institutions but foreign firms and subsidiaries as well. In the past, too many corporations and banks have simply played a shell game and relied on overseas entities to conduct their business operations in Iran.

The application of U.S. law to firms and subsidiaries residing overseas has prompted cries of 'extraterritoriality' in some circles, but such charges are misguided.

First, the term 'foreign firm' is increasingly meaningless in today's globalized economy and many of these firms avail themselves and profit in U.S. capital markets. Accordingly, it is not unreasonable for them to abide by our rules including those related to disclosure of Iran business required by the Securities and Exchange Commission.

Second, the law applies equally to firms residing here in the United States and government procurement rules in the World Trade Organization provide for clear exemptions to protect legitimate national security interests. One would be hard-pressed today to find a greater security threat to the world, not just the United States, than the threat posed by Iran.

Finally, the U.S. is hardly acting in a unilateral fashion. The provisions set out in the new law build on four rounds of sanctions passed by the UN Security Council. And, as noted above, many of the other world's leading capitals have joined Washington in adopting their own sanction laws.


At home and abroad, the implications of the new sanctions are profound and, for many companies, it is decision time.

Honeywell, for example, has received over $12 billion in federal contracts in the past decade, but has skirted U.S. sanctions law by selling security equipment and upgrading key petroleum facilities in Iran through its British subsidiary Universal Oil Products.

Similarly, Danish shipping conglomerate Maersk has received close to $4 billion in federal contracts from the U.S. government in the past 10 years and has extensive business dealings in Iran. Recently, Maersk has denied that any of its business dealings violate the new law but has clarified neither what its two offices in Iran do, nor Maersk's relationship with several container facilities in Iran. Given that Maersk was fined over $3 million in August for violating existing U.S. sanctions laws on Iran and Sudan, skepticism is wholly warranted. Under penalty of law, Maersk will now have no choice but to formally certify to the U.S. government that its actions do not violate U.S law or face possible termination of existing contracts and a prohibition of entering into new contracts for at least three years.

The most responsible path for companies to follow, of course, would be to cease doing business in Iran altogether. Many have already done so, including Caterpillar, Huntsman, General Electric, Ingersoll Rand, KPMG, Siemens and Toyota. Last week, Germany's largest steelmaker, ThyssenKrupp, joined them and announced they are pulling the plug on new business dealings in Iran in light of new US and European sanctions.

Iran's flagrant defiance of international norms should be reason enough for corporations to cease their business dealings in Iran. Now the U.S. government is presenting companies with a reasonable choice should they refuse to do so: do business with Uncle Sam or with the mullahs in Tehran.


The right course of action is clear. U.S. taxpayers no longer need foot the bill for activities that directly threaten our security, not to mention provide material support for someone who engages in malicious conspiracy theories about the most horrific terrorist attack on American soil.

 Ambassador Mark D. Wallace serves as the President of United Against Nuclear Iran. Most recently, he served as United States Ambassador to the United Nations, Representative for U.N. Management and Reform.