The U.S. government has levied additional sanctions on the Iranian financial sector that will put further strain on Tehran’s ability to access the international financial system. The designations are based upon an Executive Order President Trump issued in January 2020 giving the Secretary of State and the Secretary of Treasury the ability to impose sanctions on any part of Iran’s economy.
In short, the U.S. designated 18 additional Iranian banks last week, which effectively expanded the potential risk of secondary sanctions liability to all third parties—U.S. or non U.S. persons—that do business with them. These banks include Amin Investment Bank, Bank Keshavarzi Iran, Bank Maskan, Bank Refah Kargaran, Bank-e Shahr, Eghtesad Novin Bank, Gharzolhasaneh Resalat Bank, Hekmat Iranian Bank, Iran Zamin Bank, Karafarin Bank, Khavarmianeh Bank (also known as Middle East Bank), Mehr Iran Credit Union Bank, Pasargad Bank, Saman Bank, Sarmayeh Bank, Tosee Taavon Bank (also known as Cooperative Development Bank), and Tourism Bank.
For its part, the U.S. Department of Treasury maintains that the sanctions are targeted solely toward the Iranian regime in order to deny the government “financial resources that may be used to fund and support its nuclear program, missile development, terrorism and terrorist proxy networks, and malign regional influence.” That being said, the Treasury Department insists that a general license allowing for the continuation of humanitarian transactions has been issued.
These sanctions will place additional burden on European banks and other companies that have been working with or transacting through the now designated banks to process payments for humanitarian aid. While the Office of Foreign Assets Control (“OFAC”) has reportedly issued a general license for humanitarian transactions, all banks and companies transacting in Iran must now remain vigilant more than ever to ensure that the transactions they approve or initiate do not fall within the ambit of sanctionable conduct.
This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.
