In June 2010, Congress passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010. The sanctions are intended to persuade Iran to change its conduct as it relates to Weapons of Mass Destruction (WMD) /Nuclear proliferations.
Under this Act, U.S. Persons are prohibited from engaging in any activity with persons that meet the following criteria:
- The state and the Government of Iran, as well as any political subdivision,
agency, or instrumentality thereof;
- Any entity owned or controlled directly or indirectly by the Government of
Iran; and
- Any person to the extent that such person is, or has been, or to the extent
that there is reasonable cause to believe that such person is, or has been,
acting or purporting to act directly or indirectly on behalf of the
Government of Iran
On August 16, 2010, the Office of Foreign Assets Control ("OFAC") published the Iranian Financial Sanction Regulations, 31 CFR Part 561
- Restricts U. S. Banks from doing business with financial institutions that
have violated U.S. Sanctions against Iran
- Empowered Secretary of Treasury to restrict foreign banks from having access
to U.S. correspondent bank network – Adds new list of restrict Banks
- Enhanced due diligence requirements to ensure compliance
- Under these regulations, Treasury may prohibit, or impose strict conditions
on, foreign financial institutions' access to the U.S. financial system for
facilitating significant transactions or providing significant financial
services for a financial institution designated by the U.S.
The Comprehensive Iran Sanctions, Accountability & Divestment Act of 2010 has 4 Titles which apply to financial institutions and businesses:
Title I – Sanctions
Title II - Divestment from Certain companies that Invest in IRAN
Title III – Prevention of Diversion of Certain Goods, Services, and Technologies to Iran
Title IV – General Provisions
How to Comply with the Comprehensive Iran Sanctions, Accountability, & Divestment Act of 2010
- Conduct thorough Know Your Customer Reviews
- Identity Beneficial Owners and understand Ownership Structure
- Be aware of those Banks listed by the Secretary of Treasury
- As of September 7th, 2010 there is one Bank on this list - Europaisch -
Iransiche Handelsbank (EIH)