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ARTICLE · 13 OCTOBER 2016

OFAC Guidance On U.S. Dollar Transactions Involving Iran

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While this clarification appears to open the door to FFIs maintaining U.S. dollar accounts on behalf of Iranian parties, the potential transfer of funds to or from such accounts continues to be severely constrained.

GlobalInternational Law
Shiva Aminian
Shiva Aminian
Thomas McCarthy
Thomas McCarthy
Jonathan Poling
Jonathan Poling
Tatman Savio
Tatman Savio
Wynn Segall
Wynn Segall
Nnedinma Ifudu Nweke
Nnedinma Ifudu Nweke
Mahmoud Baki Fadlallah
Mahmoud Baki Fadlallah
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On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar transactions involving Iran; (b) when residual “secondary” U.S. sanctions on Iran can affect transactions involving affiliates of Iranian Specially Designated National (SDNs); and (c) U.S. government expectations for conduct of compliance screening and due diligence in Iran-related transactions otherwise permissible under U.S. sanctions relief implemented pursuant to the Joint Comprehensive Plan of Action (JCPOA or “the Agreement”) in January 2016.

Together, these clarifications provide guidance of particular relevance to non-U.S. financial services institutions, which, to date, have proven reluctant to support or participate in Iran-related transactions, notwithstanding sanctions relief measures under the JCPOA implemented by the United States

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