Frequently Asked Questions

149. What activities by foreign financial institutions can subject them to CISADA sanctions?

As described in the Iranian Financial Sanctions Regulations, the sanctionable activities of a foreign financial institution are: Facilitating the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass Destruction (WMD) or delivery… Read more

154. How does the Treasury Department determine whether a transaction or financial service is “significant” for purposes of the Iranian Financial Sanctions Regulations (IFSR)?

As set out in the IFSR, in determining whether a transaction or financial service is “significant,” the Treasury Department may consider: (1) the size, number, frequency, and nature of the transaction(s); (2) the level of awareness of management of the… Read more

158. Can the application of any part(s) of the Iranian Financial Sanctions Regulations (IFSR) be waived by the Department of the Treasury?

The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the sanctions under the Iranian Financial Sanctions Regulations (IFSR)  if the Secretary of the Treasury determines that a waiver is necessary to the… Read more

170. What activities can trigger sanctions on a foreign financial institution under the NDAA?

For private financial institutions, the Act mandates that the President sanction those institutions that are found to knowingly conduct or facilitate any significant transactions with a U.S.-designated Iranian financial institution or with the Central Bank of… Read more

171. Does the NDAA (National Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the Comprehensive Iran Sanctions, Accountability, and Divestment Act)?

No. Any foreign financial institution that knowingly facilitates significant transactions or provides significant financial services for a U.S.-designated, Iranian-linked financial institution can be sanctioned under section 104(c) of CISADA and section 561.… Read more

172. How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA? Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?

The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to transactions with only those Iranian financial institutions that are designated in connection with Iran’s WMD or terrorism activities and are denoted on OFAC’s List of… Read more

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

"significant financial transaction" The Iranian Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in determining what is… Read more

182. Is there a difference between entities that have been designated by the United States Government for illicit conduct, such as proliferation of weapons of mass destruction or support for terrorism, and those that are being blocked under E.O. 13599? How can I tell which entities appear on the Specially Designated National (SDN) List for which reasons?

Both blocked and designated entities appear on the SDN List. “Blocked” persons, in the context of E.O. 13599, appear on the SDN List due to the United States Government’s identification of these entities as the Government of Iran and/or as an Iranian… Read more

207. What were the criteria for Treasury's CISADA finding against Bank of Kunlun? How many other institutions were you looking at and why did you decide to take action against Bank of Kunlun?

Based on information made available to the Treasury Department, the Department has found that China’s Bank of Kunlun has knowingly facilitated significant transactions for various Iranian-linked banks designated by the United States under our WMD or terrorism… Read more

209. What happens to the correspondent and payable-through accounts held by Bank of Kunlun in the United States?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). To our knowledge, Bank of Kunlun does not currently hold correspondent accounts with U.S. financial institutions. The… Read more

210. What are the consequences for a U.S. financial institution that maintains or opens a new correspondent or payable-through account for Bank of Kunlun?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). A U.S. financial institution that maintains or opens a correspondent or payable-through account for Bank of Kunlun is… Read more

211. If a foreign financial institution continues to do business with Bank of Kunlun, could that lead to a CISADA finding against the other institution?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). Any foreign financial institution that knowingly facilitates significant transactionson behalf of designated Iranian… Read more

212. Does this finding affect Bank of Kunlun’s branches or subsidiaries around the world? Does this finding affect any holding companies?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). The prohibitions implemented as a result of today’s action apply to Bank of Kunlun and all of its offices, around the… Read more

213. Are United States financial institutions that do not hold correspondent or payable-through accounts for Bank of Kunlun required to block or reject transactions that otherwise involve Bank of Kunlun?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). No. U.S. financial institutions are not required to block or reject financial or trade transactions that involve Bank of… Read more

214. What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?

Context Information:  This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). Treasury regulations provide a 10-day period in which U.S. financial institutions are authorized to engage in the… Read more

215. What is the difference, in practical effect, between this and a designation under one of your other authorities, like E.O. 13382?

The July 31, 2012 Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) finding prohibits the opening or maintaining of correspondent accounts or payable-through accounts in the United States for Bank of Kunlun. This action does not… Read more

234. What is the effect of the National Iranian Oil Company (NIOC) determination? Are there CISADA implications?

As a result of the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 determination, NIOC now is also a person described under section 104(c)(2)(E)(i) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) as… Read more

235. What are the implications for petroleum purchase transactions involving NIOC by financial institutions and entities in countries that have received a significant reduction exception from the Secretary of State?

Significant transactions, financial services, or material support involving National Iranian Oil Company (NIOC) for the purchase of Iranian petroleum or petroleum products by a foreign financial institution or entity based in a country that has received a… Read more

256. What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012?

Significant financial transactions* knowingly conducted or facilitated by a foreign financial institution (FFI) with the Central Bank of Iran (CBI) on or after November 5, 2018 or with a designated Iranian financial institution may be subject to sanctions… Read more

266. Does the November 8, 2012 designation of National Iranian Oil Company (NIOC) under E.O. 13382 impact the scope of permissible transactions by foreign financial institutions (FFIs) in significantly reducing countries?

Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated on November 8, 2012, under E.O. 13382 for providing services and support to the IRGC.… Read more