The [IRAN] designation found on the Specially Designated Nationals (SDN) List maintained by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) has always been a point of confusion for many. What [IRAN] denotes is a designation as a Government of Iran entity under the Iranian Transactions Regulations (ITR), 31 C.F.R. Part 560. Accordingly, there are a number of banks on the SDN List because of [IRAN] designations, but that does not mean they are necessarily blocked.

This previously caused problems because clients saw the name of a particular bank on the OFAC SDN List and assumed it was blocked because it was contained on the List. However, since the ITR is not a blocking program, then such assumptions were erroneous. One example of this phenomenon was Bank Tejarat. When questioned about the nature of Bank Tejarat, I would previously inform clients that Bank Tejarat was not blocked but was on the list due its ownership by the Government of Iran. That, however, is no longer the case.

Yesterday, OFAC designated Bank Tejarat both under the Iranian Financial Sanctions Regulations and the Weapons of Mass Destruction Sanctions Regulations. In addition, OFAC designated Trade Capital Bank due to its links to Bank Tejarat. The following is a full list of the Iranian-linked designated banks, when they were designated, and why they were designated:

January 9, 2007

Bank Sepah: Designated under Executive Order (E.O.) 13382 for providing services to Iran’s missile program, Aerospace Industries Organization.

Bank Sepah International Plc., UK: Designated under E.O. 13382 for being owned or controlled by Bank Sepah.

October 25, 2007

Bank Melli: Designated under E.O.13382 for providing services to the Ministry of Defense for Armed Forces Logistics (MODAFL) and Iran’s nuclear program, Atomic Energy Organization of Iran (AEOI).

Melli Bank PLC: Designated under E.O.13382 for being owned or controlled by Bank Melli.

Arian Bank: Designated under E.O.13382 for being owned or controlled by Bank Melli.

Kargoshaee Bank: Designated under E.O.13382 for being owned or controlled by Bank Melli.

Mir Business Bank (f.k.a. Bank Melli ZAO ): Designated under E.O.13382 for being owned or controlled by Bank Melli.

Bank Mellat: Designated under E.O.13382 for providing financial services to AEOI and Novin Energy Company (AEOI financial conduit).

Mellat Bank SB CSJC: Designated under E.O.13382 for being owned or controlled by Bank Mellat.

Persia International Bank PLC: Designated under E.O.13382 for being owned or controlled by Bank Mellat.

Bank Saderat: Designated under E.O.13224 for providing services to terrorist organizations, including Hizballah.

October 22, 2008

Export Development Bank of Iran (EDBI): Designated under E.O.13382 for providing financial services to MODAFL.

Banco Internacional de Desarrollo: Designated under E.O.13382 for being owned or controlled by EDBI.

November 5, 2009

First East Export Bank: Designated under E.O.13382 for being owned or controlled by Bank
Mellat.

June 16, 2010

Post Bank of Iran: Designated under E.O.13382 for providing services to Bank Sepah.

September 7, 2010

Europaisch-Iranische Handelsbank (EIH): Designated under EO 13382 for providing financial services to Bank Sepah, Bank Mellat, EDBI, Persia International Bank, and Post Bank.

December 21, 2010

Ansar Bank: Designated under E.O.13382 for providing services to the Islamic Revolutionary Guard Corps (IRGC).

Mehr Bank: Designated under E.O.13382 for providing services to the IRGC.

Moallem Insurance Company: Designated under E.O. 13382 on December 21, 2010 for providing marine insurance to IRISL vessels.

February 17, 2011

Bank Refah Kargaran: Designated under E.O.13382 for providing services to MODAFL.

May 17, 2011

Bank of Industry and Mine (of Iran): Designated under E.O.13382 for providing services to Bank Mellat and EDBI.

January 23, 2012

Bank Tejarat: Designated under E.O.13382 for providing services to Bank Mellat, EDBI, the Islamic Republic of Iran Shipping Lines (IRISL) and MODAFL.

Trade Capital Bank: Designated under E.O.13382 for providing financial services to EDBI and for being owned or controlled by Bank Tejarat.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.