OFAC FAQ (Current) # 149 - CISADA (Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010)

Date issued: Aug. 16 2010

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TURBOFAC Commentary (487 words)

Notes:

1) "Facilitating a significant transaction or transactions or providing significant financial services for: (i) the Islamic Revolutionary Guard Corps or any of its agents or affiliates whose property and interests in property are blocked pursuant to the International Emergency Economic Powers Act (IEEPA)…"

The foregoing paragraph refers to 22 USC 8513(c)(2)(E)(i) of CISADA, implemented by 560.201(a)(5) and note thereto of the IFSR, and interpreted in part by 561.405. Together, the note to 560.201(a)(5) and 561.405 clarify that even for secondary sanctions compliance purposes, diligence expectations extend to companies that are blocked by operation of law (50% or greater ownership) as a result of their being designated as agents or affiliates of the IRGC.

Compare Section 1244(c)(2)(C)(iii) of the IFCA, which has not...