Important OFAC Iran FAQ Update Provides Clarity On US Dollar Processing And Due Diligence

On 7 October 2016 OFAC issued an update to its "Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day" (the FAQs), providing further guidance on due diligence requirements for non-U.S. persons engaged in transactions with Iran and providing an interesting clarification in respect of the processing of U.S. dollars by non-U.S. financial institutions.

The FAQs were first published on Implementation Day (16 January 2016).  The FAQs do not have the force of law themselves and are only intended by OFAC to be explanatory.  They do, however, provide helpful guidance on the changed U.S. sanctions regime after Implementation Day.