General Note re: Payment Processing for Iran-related Transactions Through, and Outside of, the U.S.

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (2323 words)

General Comment re: Payment Processing for Iran-related Transactions Through, and Outside of, the U.S.

a) Payment Processing for Iran-related Transactions Through the U.S. for Most Licensed Transactions of U.S. Persons

560.516(a) and (b) of the ITSR provide that "United States depository institutions" and "United States registered brokers or dealers in securities," and ONLY those types of entities:

"are authorized to process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran, if the transfer arises from, and is ordinarily incident and necessary to give effect to, an underlying transaction that has been authorized by a specific or general license issued pursuant to, or set forth in [the ITSR] and does not involve debiting or crediting an...