31 CFR § 561.324 - Designated Iranian financial institution.

Date issued: Feb. 27 2012

TURBOFAC Commentary (116 words)

Notes:

1) As OFAC alludes to, "Designated Iranian financial institution," as a defined term, is only pertinent to the NDAA-based sanctions (561.203), but there is substantial substantive overlap between those sanctions and CISADA-based sanctions.

As of 8/2019, there are at least two (and seemingly only two) Iranian banks that are "Designated Iranian financial institutions" for the purposes of this provision, but not subject to CISADA sanctions. Ayandeh Bank and Ghavamin Bank are both Iranian banks on the SDN list with the IRAN-TRA tag (i.e. sanctioned not only as a result of the GTSR or WMDPSR, but also not only due to EO 13599).

2) Compare with Sec. 2(a)(ii) of the EO 13846.