Comments on: All in a Name http://www.exportlawblog.com/archives/85 Latest News on DDTC, BIS, OFAC, and other export law matters Fri, 10 Feb 2012 10:06:23 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Clif Burns http://www.exportlawblog.com/archives/85/comment-page-1#comment-398 Clif Burns Thu, 11 Jan 2007 15:56:11 +0000 http://www.exportlawblog.com/archives/85#comment-398 My list of activities otherwise available to Iranian banks was not meant to be exclusive, so anonymous is quite right when he points out that U-turn transactions would be prohibited by this designation, just as they were prohibited not long ago for Iran's Bank Sederat. Anonymous is also right that the designation could result in blocked funds, whereas they previously would have been rejected. However, since rejection effectively deterred the transactions, I'm not sure that blocking will bring much more to the table, hence my question about the significance of the designation. If, however, the result of the designation is a significant amount of blocking of Bank Sepah funds, then I prepare to stand corrected. My list of activities otherwise available to Iranian banks was not meant to be exclusive, so anonymous is quite right when he points out that U-turn transactions would be prohibited by this designation, just as they were prohibited not long ago for Iran’s Bank Sederat.

Anonymous is also right that the designation could result in blocked funds, whereas they previously would have been rejected. However, since rejection effectively deterred the transactions, I’m not sure that blocking will bring much more to the table, hence my question about the significance of the designation.

If, however, the result of the designation is a significant amount of blocking of Bank Sepah funds, then I prepare to stand corrected.

]]> By: anonymous http://www.exportlawblog.com/archives/85/comment-page-1#comment-397 anonymous Thu, 11 Jan 2007 14:57:30 +0000 http://www.exportlawblog.com/archives/85#comment-397 The designation is actually quite significant. There are no blocking priveleges under the Iranian Transactions Regulations, so at the most US financial institutions could only "reject" or bounce back transactions involving Bank Sepah. Furthermore, US financial institutions were previously authorized to process commercial U-Turn transactions involving Bank Sepah. Now such transactions would be blocked. The designation is actually quite significant. There are no blocking priveleges under the Iranian Transactions Regulations, so at the most US financial institutions could only “reject” or bounce back transactions involving Bank Sepah. Furthermore, US financial institutions were previously authorized to process commercial U-Turn transactions involving Bank Sepah. Now such transactions would be blocked.

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