Banking & Financial Services

The U.S. Department of Treasury (“Treasury”) recently announced (“Announcement”) the designation of Iran’s third-largest bank, Bank Tejarat, under Executive Order 13382 – Blocking Property of Weapons of Mass Destruction (“WMD”) Proliferators and Their Supporters. Treasury designated Bank Tejarat after finding that Bank Tejarat provided financial services to: (i) Bank Mellat; (ii) the Export Development Bank of Iran (“EDBI”); (iii) the Islamic Republic of Iran Shipping Lines; and (iv) the Ministry of Defense for Armed Forces Logistics, all of which were previously designated by Treasury or the Department of State for their involvement in Iran’s WMD proliferation activities. Trade Capital Bank, a Minsk-Belarus-based bank, was also designated for providing financial services to EDBI and for being owned or controlled by Bank Tejarat.

Bank Tejarat has approximately 2,000 branches throughout Iran and foreign branches in Paris, France and Dushanbe, Tajikistan. According to Treasury, Bank Tejarat has directly facilitated Iran’s illicit nuclear efforts and assisted U.S.-designated banks in circumventing international sanctions. With the designation of Bank Tejarat and Trade Capital, a total of 23 Iranian-linked financial institutions, including all of Iran’s largest state-owned banks, have been sanctioned by the U.S. based on their involvement in Iran’s illicit activities.

Foreign financial institutions must note that the designations of Bank Tejarat and Trade Capital Bank could result in sanctions under the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (“CISADA”) for foreign financial institutions that conduct business with Bank Tejarat or Trade Capital Bank. Under CISADA, foreign financial institutions that knowingly facilitate significant transactions or provide significant financial services for an Iranian-linked financial institution designated by the U.S. face the loss of their direct access to the U.S. financial system.

To read a complete copy of the Announcement click this link. 

This publication is for general information only.It is not legal advice, and legal counsel should be contacted before any action is taken which might be influenced by this publication.

Established in 1925, Gunster Yoakley is one of Florida’s oldest and largest full-service law firms.  Its substantial and diversified practice serves an extensive client base of international, national and local businesses, institutions, local governments and prominent individuals.  The firm maintains a strong presence in Florida with offices in Fort Lauderdale, Miami, Palm Beach, Stuart, Vero Beach, West Palm Beach, Jacksonville, Tallahassee, and Tampa. Gunster Yoakley is home to more than 180 attorneys and 329 employees, providing counsel to clients through 18 practice groups including corporate, immigration, employment, technology and emerging companies, tax, banking and financial services,  real estate, land use and environmental, business litigation, and private wealth services.

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