Treasury’s Office of Foreign Assets Control (OFAC) has issued final rules to implement provisions of the National Defense Authorization Act (NDAA), which builds on the Comprehensive Iran Sanctions Accountability and Divestiture Act (CISADA)1 to impose further sanctions against Iran. Although CISADA prohibits foreign financial institutions (FFIs) from providing aid or support to the government of Iran and its Revolutionary Guard Corps to acquire weapons of mass destructions (WMDs) and their delivery systems, the new rules extend sanction coverage to the government of Iran, including its central bank, and to all blocked Iranian financial institutions designated by Treasury. Iranian Financial Sanctions Regulations (IFSR) are intended to cutoff the government of Iran from the international financial system and to penalize financial institutions that provide it with financial services.
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