211. If a foreign financial institution continues to do business with Bank of Kunlun, could that lead to a CISADA finding against the other institution?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).

Any foreign financial institution that knowingly facilitates significant transactionson behalf of designated Iranian banks – whether directly or indirectly – may face Comprehensive Iran Sanctions, Accountability, and Divestment Act(CISADA) sanctions. OFAC defines “knowingly” in this context as meaning the financial institution knew or should have known of the conduct, circumstance, or result. Bank of Kunlun has demonstrated its willingness to move hundreds of millions dollars on behalf of designated Iranian banks. Accordingly, we would expect heightened due diligence in any dealings with Bank of Kunlun.