The Office of Foreign Assets Control (“OFAC”) today released a document entitled “Notice for TSRA License Holders and Applicants.” In that document, OFAC notes that Bank Sepah, Bank Saderat, Bank Mellat and their branches and certain subsidiaries were designated pursuant to Executive Order 13382 and Executive Order 13224 and that all property of those banks was therefore blocked and U.S. persons were forbidden to deal with those banks. The Notice then stated:

Even if you are holding a valid OFAC license authorizing the exportation or reexportation of agricultural commodities, medicine or medical devices to Iran …, as of October 25, 2007, you are no longer permitted to engage in any transactions, directly or indirectly, with any of the above-listed banks.

The need for the notice was probably prompted by an ambiguity that may have been created by section 516 of the Iranian Transactions Regulations which deals with payment for transactions involving Iran. Section 516(a)(3) permits U.S. banks to process transfers of funds to or from Iran where:

The transfer arises from an underlying transaction that has been authorized by a specific or general license issued pursuant to this part ….

The Notice now makes clear that this doesn’t apply to transactions with the three designated banks.

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