Frequently Asked Questions

The Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions” to include: depository institutions, banks, savings banks, money service businesses, trust companies, insurance companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment… Read more

The Iranian Financial Sanctions Regulations (IFSR) define “ foreign financial institutions ” to include foreign depository institutions, banks, savings banks, money service businesses, trust companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment… Read more

The term “knowingly” as used in the IFSR means that a person has actual knowledge or should have known of specific conduct, a circumstance, or a result. In other words, the IFSR could be implicated if the Treasury Department finds that a foreign financial institution knew or should have known that… Read more

As set out in the IFSR , in determining whether a transaction or financial service is “ significant ,” the Treasury Department may consider: (1) the size, number, frequency, and nature of the transaction(s); (2) the level of awareness of management of the transaction(s) and whether or not the… Read more

A finding by the Treasury Department that a foreign financial institution knowingly engages in one or more of the sanctionable activities is necessary before the Treasury Department can prohibit or impose strict conditions on the opening or maintaining in the United States of correspondent accounts… Read more

As a general matter, the Treasury Department will reach out to foreign financial institutions to inquire about their conduct before making a finding . If the Treasury Department decides to impose strict condition(s), the Treasury Department will issue an order or a regulation that sets out the… Read more

Any U.S. person who violates the correspondent account provisions of the IFSR may be subject to civil penalties of up to the greater of $250,000 or twice the transaction value, and criminal penalties for willful violations of up to $1 million and 20 years in prison. A U.S. financial institution may… Read more

The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the sanctions under the Iranian Financial Sanctions Regulations ( IFSR )  if the Secretary of the Treasury determines that a waiver is necessary to the national interest of the United …

The text of the Iranian Financial Sanctions Regulations (IFSR) can be found here .  …

E.O. 13599 requires U.S. persons to block (i.e., freeze) all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, which also includes the Central Bank of Iran. This means that all individuals and entities that… Read more