U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of primary money laundering concern

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.

Please see full Publication below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Hogan Lovells | Attorney Advertising

Written by:

Hogan Lovells

Hogan Lovells on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.