Frequently Asked Questions

204. Will Treasury pursue an enforcement action before identifying or listing a person pursuant to Executive Order 13608?

204 … The authorities granted under this Executive Order are in addition to current authorities that Treasury has to pursue an enforcement action for violations of U.S. law, and Treasury is not required to pursue a civil enforcement action prior to identifying or listing a person pursuant to… Read more

207. What were the criteria for Treasury's CISADA finding against Bank of Kunlun? How many other institutions were you looking at and why did you decide to take action against Bank of Kunlun?

207 … Based on information made available to the Treasury Department, the Department has found that China’s Bank of Kunlun has knowingly facilitated significant transactions for various Iranian-linked banks designated by the United States under our WMD or terrorism authorities. Upon finding that… Read more

208. How are you defining “significant” transactions and financial services?

208 … In determining whether transactions or financial services are significant , the Secretary of the Treasury may consider a number of factors related to the transactions or services, including, but not limited to: size, number, and frequency; type, complexity and commercial purpose; the level of… Read more

209. What happens to the correspondent and payable-through accounts held by Bank of Kunlun in the United States?

209 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . To our knowledge, Bank of Kunlun does not currently hold correspondent accounts with U.S. financial institutions. The July 31, 2012 action prohibits… Read more

210. What are the consequences for a U.S. financial institution that maintains or opens a new correspondent or payable-through account for Bank of Kunlun?

210 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . A U.S. financial institution that maintains or opens a correspondent or payable-through account for Bank of Kunlun is subject to civil penalties in the… Read more

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?

211 … 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… Read more

212. Does this finding affect Bank of Kunlun's branches or subsidiaries around the world? Does this finding affect any holding companies?

212 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . The prohibitions implemented as a result of today's action apply to Bank of Kunlun and all of its offices, around the world. … Does this finding affect Bank… Read more

213. Are United States financial institutions that do not hold correspondent or payable-through accounts for Bank of Kunlun required to block or reject transactions that otherwise involve Bank of Kunlun?

213 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . No. U.S. financial institutions are not required to block or reject financial or trade transactions that involve Bank of Kunlun. That said, we would expect… Read more

214. What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?

214 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . Treasury regulations provide a 10-day period in which U.S. financial institutions are authorized to engage in the transactions necessary to close an… Read more

215. What is the difference, in practical effect, between this and a designation under one of your other authorities, like E.O. 13382?

215 … The July 31, 2012 Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) finding prohibits the opening or maintaining of correspondent accounts or payable-through accounts in the United States for Bank of Kunlun. This action does not require the immediate freezing of any… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence