On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran.

Foreign governments and foreign financial institutions that choose to participate in this enhanced due diligence process must report to the U.S. Treasury Department a significant volume of information on a monthly basis. Foreign financial institutions that choose not to participate in this process could face exposure under U.S. "secondary" sanctions if Specially Designated Nationals targeted by other sanctions programs (beyond the Iran sanctions program), such as the Central Bank of Iran (CBI), which is designated under global terrorism sanctions, are involved in their payment process, or the transaction does not otherwise meet the requirements of applicable general or specific licenses.