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Effective February 27, 2012, the U.S. Office of Foreign Assets Control (OFAC) issued a final rule (the “Rule”) implementing Section 1245(d) of the National Defense Authorization Act for Fiscal Year 2012 (NDAA), which requires the imposition of sanctions on the Central Bank of Iran and designated Iranian financial institutions
On October 5, 2011, the Financial Crimes Enforcement Network at the U.S. Department of the Treasury (FinCEN) released final regulations to implement Section 104(e) of CISADA that contain compliance obligations specific to banks in the United States, including U.S. offices of foreign banks
Following up on our June 25, 2010, client advisory (“U.S. Congress Agrees to Iran Sanctions Overhaul with Broad Extraterritorial Reach”) regarding enactment of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury on April 27, 2011 issued proposed regulations to implement Section 104(e) of CISADA
