US Sanctions 18 Iranian Banks

The Office of Foreign Assets Control announced a range of sanctions targeting 17 major Iranian banks for operating in the country’s financial sector and one Iranian bank for being affiliated with the Iranian military. The agency also issued a general license authorizing certain transactions with the banks and announced a 45-day wind-down period for activities involving non U.S. people and companies.

The Treasury Department said Oct. 8 the banks help fund the Iranian government’s “malign activities,” including nuclear weapons and missile development. Treasury Secretary Steven Mnuchin said the U.S. will continue to impose sanctions “until Iran stops its support of terrorist activities and ends its nuclear programs.”

OFAC issued General License L, which authorizes certain transactions with the banks, and issued frequently asked questions 842, 843, 844 and 847 to clarify the scope of the license and the possibility of secondary sanctions on non-U.S. people and companies. The FAQs also cover humanitarian trade and stress the sanctions do not “affect existing authorizations and exceptions” for trade in agricultural goods, food, medicine or medical devices.

In FAQ 845, OFAC announced a 45-day wind-down period for non-U.S. persons involved in transactions with the Iranian financial sector or the sanctioned Iranian banks. OFAC said the period ends Nov. 22 and stressed that “non-U.S. persons engaged in certain activities involving” the Iranian banks after that period may be exposed to sanctions.” But the agency also said it “continues to analyze” whether some transactions may be “non-significant” and therefore may not warrant sanctions under the wind-down period. OFAC said it plans to issue more guidance on those transactions and activities.

The agency clarified in FAQ 846 that waivers issued by the State Department and exceptions outlined in the Iranian Freedom and Counter-proliferation Act of 2012 remain valid and “activities conducted under them” involving the sanctioned banks are “not sanctionable” during the wind-down period. But OFAC said “the State Department, in consultation with OFAC, continues to assess whether these waivers and exceptions require modification prior to the close of the wind-down period to account for” the new sanctions.

Most of the sanctioned banks were designated using a January executive order that expanded U.S. sanctions authority against Iran (see 2001100050). The banks are: Amin Investment Bank, Bank Keshavarzi Iran, Bank Maskan, Bank Refah Kargaran, Bank-e Shahr, Eghtesad Novin Bank, Gharzolhasaneh Resalat Bank, Hekmat Iranian Bank, Iran Zamin Bank, Karafarin Bank, Khavarmianeh Bank, Mehr Iran Credit Union Bank, Pasargad Bank, Saman Bank, Sarmayeh Bank, Tosee Taavon Bank, Tourism Bank and Islamic Regional Cooperation Bank.