Some American and Canadian companies are not content to wait for Iran sanctions to be lifted. To get a head start upon their competition, US & Canadian banks, as well as large non-financial companies, have resorted to engaging third-party corporations, which act in a representative capacity, as agents, to sign agreements, and jump what will be a long line. when and if sanctions are removed on Iran.
The problem is, OFAC is nowhere to be seen, and one hopeS that it is not for purely political reasons. The law should be enforced, and if it turns out that the offending banks and companies are large contributors to a certain political party, and that is why they are bulletproof, and sanction-proof, and on the ground in Tehran, an investigation should ensue.
These new contractual arrangements are being made in the open, and publicly. One such agent corporation is located in Canada, and the other in the United States. Major banks are involved, including two from the US that concentrate their business on prepaid card sales; a major Canadian bank is also using the cut-out to evade sanctions.
Gentlemen, the sanctions remain in place; any entity that dares to leapfrog over them, and sign contracts while sanctions still are the law runs the risk of mega-fines and civil penalties. Don't think that a subsequent lifting of sanctions will cure the violations. Do you remember that civil fines & penalties were levied for Iraq sanctions violations, long after the invasion and restoration of normal trade.