WILL IRANIAN SANCTIONS EVADERS UTILISE GENERAL LICENSE C ?

OFAC has issued what it calls General License C, a limited exemption for non-governmental organisations (NGO) who wish to send funds in support of relief efforts assisting recovery from the earthquake that struck northern Iran on 11 August. It limits eligible entities to NGOs that are tax exempt, and the amount of the relief cannot exceed $300,000, and will expire in 45 days.

The license, known as Funds Transfers related to Earthquake Relief Efforts, in the hands of an adroit money launderer, could become a useful tool for sanctions evasion, as prior notice to regulators is not required. Ensure that, if a client notifies you that it intends to utilise License C to send funds to Iran, that you have thoroughly examined both the transaction, and the client, before approving same, and wiring funds.There is also a mandatory report that your client must file; you need to have a copy of that from in your file. The license* should be reviewed by bank counsel, who may propose additional protective steps to perform in advance of the wiring of the funds for the client.

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*http://www.treasury.gov/resource-center/sanctions/Program/Document/iran_glc.pdf