In recent months, the U.S. government has stepped up its attempts to isolate Iran from any access to the U.S. financial system. Most direct access generally has been prohibited under economic sanctions that have been in place since 1979.
On Oct. 11, 2011, the Federal Register published a final rule, issued by the Financial Crimes Enforcement Network (FinCEN), the U.S. Treasury Department’s anti-money laundering agency, that implements section 104 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).1 The section prohibits or restricts banks in the United States, including U.S. offices of non-U.S. banks, from maintaining correspondent accounts for non-U.S. banks that may be engaged in activity that benefits the government of Iran, Iran’s Revolutionary Guard Corps (IRGC) or any of its agents or affiliates that are subject to U.S. economic sanctions imposed under the International Emergency Economic Powers Act (IEEPA).2 CISADA also requires that those banks more closely monitor transaction activity by the non-U.S. bank through its U.S. correspondent account.
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