Adam Szubin, formerly the Director of OFAC, and now the Acting Undersecretary for Terrorism and Financial Crimes, at his confirmation hearing, asserted that, should any Iranian bank, released from sanctions, due to the comprehensive nuclear agreement, re-offend, meaning conducting any transactions with Hezbollah or the IRGC Quds Force, American sanctions will be reimposed forthwith.
If your international trading clients are contemplating commerce with Iranian companies, the odds are those companies bank with Iranian banks currently sanctioned. considering that Iran has a well-constructed web of financial institutions, in third-world countries that do not comply with any international WMD and ballistic missile sanctions, the newly-unsanctioned banks might be tempted to utilize those pathways to continue to send funds to Hezbollah and Quds Force, and thereafter possibly be exposed.
You do not want to be sending funds to a bank the day after it is sanctioned again, nor accepting funds, sent to you through a circuitous route, by a re-sanctioned bank. Therefore, it would be prudent to check, twice daily, for any sanctions news, involving Iranian banks, at all times when your clients are engaged in ongoing transactions with Iranian clients, suppliers, vendors. or customers. Set alerts for all OFAC announcements, and have a senior member of your staff be the designated monitor of financial and sanctions news from Iran.
To do anything less results in increased risk; watch those post-agreement sanctions closely. Do you have clients affected ? Do they have pending funds transfers of receivables ? Watch yourself here.
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