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Treasury Gets New Authority for Iran-Related Sanctions, Acts Against Two Banks

President Obama signed an Executive Order "Authorizing Additional Sanctions With Respect to Iran." It gives new sanctions authorities to the Department of the Treasury and the Department of State, including authorizing Treasury to impose financial sanctions on foreign financial institutions found to have knowingly conducted or facilitated certain significant financial transactions with the National Iranian Oil Company or Naftiran Intertrade Company, or for the purchase or acquisition of petroleum or petroleum products from Iran through any channel.

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It also gives Treasury new authority to impose sanctions on foreign financial institutions found to have knowingly conducted or facilitated significant transactions for the purchase of petrochemical products from Iran. It also allows Treasury to block the property and interests in property of any person determined to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, NICO, or the Central Bank of Iran, or the purchase or acquisition of U.S. bank notes or precious metals by the Government of Iran.

At the same time, Treasury announced new sanctions under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), against two financial institutions for knowingly facilitating significant transactions or providing significant financial services for designated Iranian banks. The financial institutions sanctioned today by the Office of Foreign Assets Control (OFAC) are Bank of Kunlun in China and Elaf Islamic Bank in Iraq. The action effectively bars them from directly accessing the U.S. financial system, so financial institutions may not open correspondent or payable-through accounts for Bank of Kunlun or Elaf Islamic Bank in the U.S. and any financial institutions that currently hold such accounts must close them within 10 days.

The following entities have been added to OFAC's List of Foreign Financial Institutions Subject to Part 561 (the “Part 561 List”) :

  • BANK OF KUNLUN CO LTD (f.k.a. KARAMAY CITY COMMERCIAL BANK CO LTD.; f.k.a. KARAMAY URBAN CREDIT COOPERATIVES), 172 Xibin Rd, Ranghulu District, (Daqing, Heilongjiang Branch), Daqing 163453, China; 9 Dongzhimen North Street, Dongcheng District, (Head Office), Beijing 100007, China; No. 7 Century Ave, (Registered Office), Xinjiang, Karamay 834000, China; No. 68 Zhongya South Rd, Economic and Technological Development Zone, (Urumqi, Xinjiang Branch), Urumqi 830026, China; SWIFT/BIC CKLB CN BJ [561LIST].
  • ELAF ISLAMIC BANK, PO Box 3440, Building No. 14, Street 99, Hai Al Wehda-Mahala 902, Alweih, Baghdad, Iraq; SWIFT/BIC ELAF IQ BA; Note: The entity being designated, "Elaf Islamic Bank, Iraq" is separate and distinct from the similarly named entity, "Elaf Bank, Bahrain" [561LIST].