645. How will the re-imposition of sanctions on November 5, 2018 impact the provision of specialized financial messaging services to Iranian financial institutions?

Following the re-imposition of U.S. sanctions on November 5, 2018, sanctions that had previously been lifted or waived as part of U.S. commitments under the Joint Comprehensive Plan of Action (JCPOA) will come back into effect in their entirety, including sanctions on the provision of specialized financial messaging services to certain Iranian financial institutions.
As of November 5, 2018, sanctions on the provision of specialized financial messaging services set forth in section 220 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) snap back in full. This authority provides for sanctions on specialized financial messaging services to the Central Bank of Iran or Iranian financial institutions designated in connection with Iran’s support for terrorism or its proliferation of weapons of mass destruction (WMD) and WMD delivery systems, as set out in subsection 104(c)(2)(E)(ii) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) (see section 220 of the TRA). Such Iranian financial institutions are listed on the SDN List and carry the “[IFSR]” tag.
Furthermore, knowingly providing significant financial, material, technological, or other support to Iranian persons on the SDN List, other than Iranian financial institutions blocked solely pursuant to E.O. 13599 and listed on the SDN List with only the “[IRAN]” tag, is sanctionable for persons in countries that have not received a significant reduction exception (see subsection 1244(c)(1) of IFCA).
To avoid potential sanctions exposure, providers of specialized financial messaging services should discontinue the provision of such services to the Central Bank of Iran and any Iranian financial institutions designated in connection with Iran’s WMD proliferation, support for terrorism, or human rights abuses. The Central Bank of Iran and such designated Iranian financial institutions will have “Subject to Secondary Sanctions” listed in the “Identifications” feature in their entry on the SDN List.
Given that the U.S. government will continue to apply maximum financial pressure on the Iranian regime, including potential additional designations of Iranian financial institutions, the SDN List should be consulted regularly to determine which Iranian financial institutions have been designated.