PRINT
Financial Channels to Facilitate Humanitarian Trade with Iran and Related Due Diligence and Reporting Expectations
The U.S. Government has levied unprecedented economic pressure to disrupt the Iranian regime’s ability to covertly and illicitly access the international financial system to finance terrorism abroad, increase its domestic oppression, support the brutal Assad regime, procure ballistic missile technology, and broadly destabilize the Middle East. These U.S. government efforts are directed at the Iranian regime. They are not directed at the people of Iran, who themselves are victims of the regime’s oppression, corruption, and economic mismanagement.
The United States maintains broad exceptions and authorizations for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons, provided such transactions do not involve persons designated in connection with Iran’s proliferation of weapons of mass destruction (WMD), or Iran’s support for international terrorism. These...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) This document was released concurrent with FINceN "Imposition of Fifth Special Measure against the Islamic Republic of Iran as a Jurisdiction of Primary Money Laundering Concern." [1]
The FINceN determination imposed restrictions, not administered by OFAC, on foreign financial institutions’ (FFIs) correspondent accounts at covered U.S. financial institutions with respect to the processing of transactions involving Iranian financial institutions.
See also "Treasury and State Announce New Humanitarian Mechanism to Increase Transparency of Permissible Trade Supporting the Iranian People." [2]
From a strictly legal perspective, the "humanitarian mechanism" does not alter the scope of any OFAC-administered sanctions provision. Presumably, failure to use the mechanism will factor into whether, in the event that an FFI engages in potentially sanctionable conduct, the FFI is deemed to have "knowingly" done so. Likewise, use of the...