#OFAC IRAN SANCTIONS UPDATE SERIES#

and North Korean leaders-the United States suspended a series of high-profile military exercises with South Korea, but the declaration it signed with North Korea did not produce tangible steps for denuclearization or sanctions relief. President Donald Trump and Kim Jong-un-the first summit between sitting U.S. After the June 2018 meeting in Singapore between U.S. Several rounds of bilateral and multilateral negotiations on denuclearization dating back to the 1990s have failed. They say Kim has witnessed governments in Ukraine, Iraq, and Libya be overthrown after giving up their nuclear weapons and that he is determined not to make the same mistake. Combined Forces Command, for Foreign Affairs. Current leader Kim Jong-un sees nuclear weapons as “a military asset, an insurance policy, and a vast source of prestige all in one,” write Vincent Brooks and Ho Young Leem, former leaders of the Republic of Korea–U.S. It carried out its first nuclear test three years later. The DPRK ratified the Nuclear Nonproliferation Treaty in 1985 but withdrew in 2003, citing U.S. military bases in the region, as well as the war games the United States regularly holds with its allies, as a threat to its existence. financial institution to repeat due diligence that bank customers have performed on their own Iranian customers unless the financial institution has reason to believe that such due diligence is insufficient.North Korea’s leadership, under successive Kims, considers nuclear weapons the sole means to guarantee its survival. OFAC clarified, however, that it does not expect a non-U.S. financial institutions include performing due diligence on their own customers.

Finally, OFAC reiterated that best practices for non-U.S.

person should ensure that due diligence reflects its internal risk assessment, best practices of the relevant industry, and due diligence expectations in its local jurisdiction. In addition to such screening, OFAC suggested that a non-U.S. persons might require more than screening the names of the potential counterparties against the SDN List.

OFAC stated that sufficient due diligence on potential Iranian counterparties for non-U.S.

persons should exercise caution when engaging in such transactions to ensure no SDN is involved. persons to engage in transactions with entities that are controlled or minority owned by an Iranian or Iran-related person on the SDN List.

In the new due diligence FAQs, OFAC advised that it is not necessarily sanctionable for non-U.S.

These changes may not be pursued to facilitate any particular transaction involving Iran.

#OFAC IRAN SANCTIONS UPDATE LICENSE#

entity or its owned-or-controlled foreign entity multiple times to enable the foreign entity to engage in transactions pursuant to General License H. person to change the operating policies and procedures of a U.S.

OFAC reiterated that General License H authorizes a U.S.

The FAQs indicate that such Iranian financial institutions may not be on the SDN List. financial institutions may transact with non-U.S., non-Iranian financial institutions that do business with Iranian financial institutions.

persons in such transactions unless such transfers are authorized by OFAC or exempt from the prohibitions under U.S. dollar transactions involving Iran through the U.S.

financial institutions are still prohibited from clearing U.S. dollar clearing transactions involving Iran that begin and end with non-U.S., non-Iranian financial institutions.

OFAC reaffirmed the prohibition against “U-Turn” transactions, i.e., U.S.

person, or any person on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List). financial institutions may occur provided that the transactions or accounts do not involve, directly or indirectly, the U.S. dollar denominated accounts that involve Iran. financial institutions may process transactions denominated in U.S.

In the updated FAQs, OFAC reiterated its position that non-U.S.persons engaging in transactions with or involving Iran. OFAC also added three FAQs to provide guidance on due diligence practices for non-U.S. Rather, OFAC amended the June 2016 version of the FAQs to clarify and reiterate its position on certain banking practices related to Iran and on activities under General License H. These FAQs do not reflect any changes or relaxation of U.S. For more information on the June 2016 updated guidance, please see our blog post here. These updates provide clarification on existing OFAC guidance originally issued in January 2016 and most recently updated in June 2016.

Sanctions under the Joint Comprehensive Plan of Action (JCPOA). Treasury Department’s Office of Foreign Assets Control (OFAC) updated its list of Frequently Asked Questions (FAQs) Relating to the Lifting of Certain U.S.

Ofac iran sanctions update