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237. How does the effect of this determination compare to the effect of section 1(a) of Executive Order 13622 as to transactions with National Iranian Oil Company (NIOC)?


The effect of the determination is similar to the effect of Executive Order 13622 section 1(a), which provides for prohibitions on the opening of and prohibitions or strict conditions on maintaining correspondent accounts or payable-through accounts in the United States for foreign financial institutions determined by the Secretary of the Treasury, in consultation with the Secretary of State, to have knowingly conducted or facilitated significant financial transactions with NIOC. Executive Order 13622 likewise contains an exception that covers transactions with NIOC conducted or facilitated by foreign financial institutions based in NDAA-excepted jurisdictions. A significant difference between these authorities is that the National Defense Authorization Act (NDAA) exception in the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 is limited to transactions or financial services for the purchase of petroleum or petroleum products from Iran.