Guidance
From OFAC's FAQ on how to determine if you have a match against the SDN list, we have: Step 3. How much of the SDN’s name is matching against the name of your account holder? Is just one of two or more names matching (i.e., just the last name)? If […]
Her Majesty's Treasury made some notable updates to their site yesterday. First, the frequently asked questions (FAQ) page was enhanced with additional sections for: · advice for designated persons on how they may use their assets, · advice on humanitarian transactions, · information on what constitutes ownership and control, · […]
The question (No 318): Does the GL for basic medical supplies authorize the export of all medical devices? The answer: No. The GL for basic medical supplies appearing at section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations (“ITSR”) authorizes the export or reexport to Iran of items defined in […]
The question (No 312): How does the Executive Order tighten the financial sanctions applicable to FFIs under section 1247 of IFCA? The answer: Section 3 of the E.O. tightens the financial sanctions applicable to FFIs under section 1247 of IFCA and provides for correspondent and payable-through account sanctions on FFIs […]
The question (No 310): What is considered Iran’s automotive sector for purposes of the Executive Order? The answer: The E.O. authorizes the imposition of correspondent and payable-through account and Iran Sanctions Act-style sanctions for certain transactions, on or after July 1, 2013, for the sale, supply, or transfer to Iran […]
The question (No 309): What transactions involving the Iranian rial will be subject to sanctions? The answer: FFIs risk correspondent and payable-through account and blocking sanctions for (i) knowingly conducting or facilitating, on or after July 1, 2013, significant transactions related to the purchase or sale of Iranian rials or […]
The question (No 308): What are the implications of the material assistance provision of the Executive Order? The answer: Subsection 2(a)(i) of the E.O. authorizes the Department of the Treasury to block the property and interests in property of persons determined to have materially assisted, sponsored, or provided financial, material, […]
The question (No 306): How does the Executive Order relate to the IFCA provisions? The answer: The E.O. provides additional tools related to the IFCA provisions by: a. Authorizing prohibitions or restrictions on the importation of goods; and b. Implementing the statutory requirements of section 105C of the Comprehensive Iran […]
The question (No 305): Sanctions under section 1247 of IFCA apply to FFIs that facilitate financial transactions on behalf of an Iranian person on the SDN List. How does the Executive Order relate to section 1247? The answer: The E.O. tightens the financial sanctions applicable to FFIs under section 1247 […]
The question (No 303): Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under section 1246(a)(1)? The answer: A number of insurance activities are subject to sanctions under IFCA, including providing insurance, reinsurance, or underwriting services to persons on the SDN List sanctioned for activities with respect to […]
Mr. Watchlist 