Financial Crime World

Here is the article in markdown format:

Iran’s Financial Institutions Face Sanctions Risk, Non-US Entities Take Notice

Washington D.C. - The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated several Iranian financial institutions, sparking a renewed sanctions risk for non-US entities.

A Renewed Sanctions Risk

The designations, which have not been seen since before the implementation of the Joint Comprehensive Plan of Action (JCPOA), put these institutions at risk of being considered “significant” under OFAC’s sanctions regime. This could lead to secondary sanctions, potentially impacting non-US entities that transact with them.

Key Actions to Take

To mitigate this risk, companies are advised to take immediate action to assess their risks and develop a plan for each affected transaction. This includes:

  • Identify potential dealings with listed banks: Even if there are no current transactions, companies should ensure they have proper controls in place to guard against future dealings.
  • Determine significance: Companies must assess whether a transaction or series of transactions might be considered “significant” under OFAC’s sanctions regime.
  • Obtain licenses or exemptions: Licenses or existing exemptions may be available to authorize transactions, but companies should undertake an analysis to confirm they have the necessary internal controls in place.
  • Understand risks: Conduct risk assessments to identify and anticipate compliance challenges, and develop a process for mitigating them.
  • Review written policies and procedures: Ensure sanctions compliance programs are adequate and compliant with applicable regulatory standards.

KPMG’s Expertise

KPMG’s Export Controls & Sanctions and Financial Crimes & Analytics practices have deep technical knowledge of US and global sanctions regimes, as well as practical experience in implementing compliance measures. Our team can help companies navigate the complex export controls and sanctions landscape, from assessing risk profiles to implementing compliance procedures.

Contact Us

For more information or to schedule a consultation, please contact:

  • Steven Brotherton, Principal, Global Export Controls & Sanctions Lead - sbrotherton@kpmg.com - 415-963-7861
  • Edwige A. Sacco, Principal, Financial Crimes, KPMG Risk Advisory Solutions - esacco@kpmg.com - 703-855-0803