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ARTICLE · 15 OCTOBER 2020

Treasury Sanctions Iranian Financial Sector

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The Secretary of the Treasury, in consultation with the Secretary of State, authorized sanctions under Executive Order 13902 ("Imposing Sanctions With Respect to Additional Sectors of Iran") against any persons -

United StatesInternational Law
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The Secretary of the Treasury, in consultation with the Secretary of State, authorized sanctions under Executive Order ("E.O.") 13902 ("Imposing Sanctions With Respect to Additional Sectors of Iran") against any persons - Iranian or otherwise - determined to "operate" in the Iranian financial sector. In accordance with this action, OFAC added 18 Iranian financial institutions to the Specially Designated Nationals and Blocked Persons List.

OFAC issued a General License ("GL") and other authorizations to limit the immediate impact of these restrictions on the Iranian financial sector. First, under GL L, OFAC authorized continued dealings with the 18 sanctioned Iranian financial institutions - so long as those transactions are not prohibited by the Iran Transactions and Sanctions Regulations ("ITSR"). As explained in OFAC's FAQ 842, U.S. persons may continue to engage in transactions involving the sanctioned Iranian financial institutions, if done pursuant to a valid

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