Notice to Foreign Financial Institutions Conducting Business with Iran

Date issued: Oct. 05 2026

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TURBOFAC Commentary (94 words)

Notes:

1) “Alert” describes secondary sanctions actions and designation intent vis-à-vis the Iranian banking sector following the Determination Pursuant to Executive Order 13902 - Aviation, Digital Asset, Gold, Shipping, and Technology Sectors of the Iranian Economy. Note that, notwithstanding the Alert, FAQ # 7 remains in effect (“non-U.S. persons do not generally risk being sanctioned for engaging in or facilitating transactions for which a U.S. person would not require a specific license.”) This would cover payment processing involving Iranian banks for authorized transactions, but not maintenance of correspondent accounts and similar types of transactions.