257 … As of February 6, 2013, 20 jurisdictions have been granted a 180-day significant reduction exception . The following jurisdictions received their 180-day significant reduction exception to the National Defense Authorization Act (NDAA) sanctions on September 14, 2012: Belgium, the Czech… Read more
258 … OFAC interprets bilateral trade between Iran and the country with primary jurisdiction over the FFI to mean trade in only those goods or services originating in (e.g., produced in or substantially transformed in) – (i) the country with primary jurisdiction over the FFI conducting or… Read more
259 … Section 504 of the TRA requires that, in order for a sanctionable transaction to fall within the bounds of the significant reduction exception , any funds owed to Iran as a result of the bilateral trade transaction must be credited to an “account located in the country with primary… Read more
149 … As described in the Iranian Financial Sanctions Regulations , the sanctionable activities of a foreign financial institution are: Facilitating the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass Destruction (WMD) or delivery systems for WMD or to provide support… Read more
150 … The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of “designated” persons, which refers both to natural persons (i.e., individuals) and legal persons (such as corporations and other entities). The most recent list of… Read more
153 … 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… Read more
154 … 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
155 … 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… Read more