The Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010. This act enables the U.S. Treasury to prohibit or impose conditions on opening or maintaining U.S. correspondent banking or payable-through accounts for a non-U.S. financial institution found to knowingly engage in sanctionable activities. This includes those entities that facilitate (i) Iran’s WMD acquisition or development, or Iran’s support for international terrorism; or (ii) significant transactions or providing significant financial services for designated banks or for Iran’s Islamic Revolutionary Guard Corps or its affiliates, which include large commercial enterprises. After CISADA was signed into law, Treasury has reportedly engaged with over 120 financial institutions and bank regulators in more than 60 countries all over the world to brief them on the financial provisions of CISADA. In July 2012, Treasury first exercised its CISADA authorities when it announced that US financial institutions would be prohibited from opening or maintaining accounts for China’s Bank of Kunlun and Iraq’s Elaf Islamic Bank. Acting to expose and isolate Iranian financial institutions connected to Iran’s WMD proliferation or support for terrorism, the Treasury Department imposed sanctions against two dozen Iranian banks.  As financial institutions around the world have cut ties with these designated Iranian banks, Bank of Kunlun and Elaf Islamic Bank took the opposite approach by providing financial services to designated Iranian banks and facilitating the movement of millions of dollars worth of international transactions. 4 Following “Implementation Day” in January 2016, the day when the International Atomic Energy Agency, or IAEA, says that Iran has curbed its nuclear program enough to begin relief on sanctions, some CISADA sections have been amended, or deleted. However, other sections continue to apply: For example, section 104(c)(2)(E)(ii)(I) of CISADA continues to apply to foreign financial institutions that knowingly facilitate a significant transaction or transactions or provide significant financial services for a person whose property or interests in property are blocked in connection with Iran’s proliferation of WMD. In addition, after Implementation Day, correspondent and payable-through account sanctions under section104(c)(2)(E)(ii)(II) of CISADA continue to apply to foreign financial institutions that knowingly facilitate a significant transaction or transactions or provide significant financial services for a person whose property or interests in property are blocked in connection with Iran’s support for international terrorism.

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