Consolidated Comment on the Sanctioning of the Iranian Financial Sector Pursuant to E.O. 13902, General License L and Related FAQs Issued on 10-8-2020

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TURBOFAC Commentary (3453 words)

Consolidated Comment on the Sanctioning of the Iranian Financial Sector Pursuant to E.O. 13902, General License L and Related FAQs Issued on 10-8-2020

I. BACKGROUND

On Oct. 8, 2020, OFAC “identified the financial sector of the Iranian economy” as subject to its sectoral determination pursuant to Sec. 1(a)(i) of Executive Order 13902 (“EO 13902”). Sec. 1(a)(i) of EO 13902 allows for the blocking of all persons affirmatively determined by the Treasury Department to “operate in” certain designated sectors of the Iranian economy. As of Oct. 8, this includes the “financial sector.” Concurrent with this announcement, OFAC blocked 18 Iranian individual banks pursuant to EO 13902. 17 of those banks had previously appeared on SDN list with only the [IRAN] program tag, but now appear with both the [IRAN] and [IRAN-EO13902] program tags.

The practical consequences...