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OFAC Issues Final Rule Amending Iranian Financial Sanctions Regulations

The Office of Foreign Assets Control has issued a final rule, effective February 27, 2012, amending the Iranian Financial Sanctions Regulations (IFSR) and reissuing them in their entirety, in order to, among other things, implement section 1245(d) of the National Defense Authorization Act for FY 2012 (NDAA), which provides for the imposition of sanctions with respect to the Central Bank of Iran and designated Iranian financial institutions.

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OFAC's final rule makes the following changes to the IFSR:

  • Implements section 1245(d) of the NDAA (and other related provisions of section 1245), which provides for the imposition of sanctions on foreign financial institutions that conduct significant business with the Central Bank of Iran and designated Iranian financial institutions
  • Implements Executive Order 13599 (Blocking Property of Iran and Iranian Financial Institutions)
  • Removes references to a list of foreign financial institutions barred from maintaining correspondent or payable-through accounts with U.S. financial institutions at Appendix A and replaces references to Appendix A with references to a list on OFAC’s website
  • Modifies reporting requirements
  • Makes technical changes or corrections.

(On December 31, 2011, President Obama signed into law the NDAA, which, among other things, established sanctions on foreign financial institutions that conduct significant business with the Central Bank of Iran. The President then signed EO 13599 on February 5, 2012, which included measures to implement NDAA provisions related to the Iran sanctions program and freezes all property of the Central Bank of Iran and all other Iranian financial institutions, as well as all property of the government of Iran. See ITT’s Online Archives 12010615 for summary of NDAA, including provisions relating to the Central Bank of Iran. See also ITT’s Online Archives 12020710 for summary of EO 13599.)