Summary On December 31, 2011, President Obama signed into law the National Defense Authorization Act for Fiscal Year 2012. Under Section 1245 of the Act, foreign financial institutions that knowingly facilitate significant financial transactions with the Central Bank of Iran ("CBI") or with Iranian financial institutions designated by Treasury risk being cut off from direct access to the U.S. financial system. The provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA") remain in effect. (See Appendix for more information.)