The U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), has issued new Iranian Financial Sanctions Regulations (IFSR) limiting access to the U.S. banking system of foreign financial institutions upon a finding by the United States that the financial institution (a) facilitates Iran’s development of nuclear weapons or (b) provides financial services either to Iran’s Islamic Revolutionary Guard Corp (IRGC) or to any financial institution whose property is blocked in connection with Iran’s nuclear development or support of terrorism. The foreign financial institutions subject to these new prohibitions will be listed in an “Appendix A” to the new regulations, 31 C.F.R. Part 561. These regulations were issued under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). See, 75 Fed. Reg. 49,836.
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