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Legal Briefing
New US economic sanctions create risks for non-US financial institutions
Practice Area: Regulation and Compliance
Sector: Investment Management
Jurisdiction: USA
Published: 02 September 2010
Law Firm: Shearman & Sterling
Overview
The US Treasury Department has issued new regulations implementing provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (the Sanctions Act).
The new rules are effective immediately and prohibit or severely restrict non-US financial institutions that knowingly engage in certain activities involving Iran from having US correspondent accounts. The rules also prohibit any person or entity owned or controlled by a US financial institution from engaging in transactions involving the Islamic Revolutionary Guard Corps (the Revolutionary Guard) or related entities.
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