2012 Letter From Szubin to Emerson in re: SWIFT (Incoming letter included)

Date issued: Mar. 21 2012

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TURBOFAC Commentary (110 words)

Notes:

1) See information related to the EU decision at https://www.swift.com/insights/press-releases/swift-instructed-to-disconnect-sanctioned-iranian-banks-following-eu-council-decision (SWIFT instructed to disconnect sanctioned Iranian banks following EU Council decision), https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:077:0018:0018:EN:PDF (EU Council Decision) and https://www.nytimes.com/2012/03/16/world/middleeast/crucial-communication-network-expelling-iranian-banks.html ("Global Network Expels as Many as 30 of Iran’s Banks in Move to Isolate Its Economy").

Note the disconnect between the Congresswoman's letter (referring to GOI-linked banks), the scope of the IFSR ("designated Iranian financial institutions") and the banks to which the March 15, 2012 EU Council Decision applied.