Lots of news lately on Iran sanctions, so here’s a summary and some links.

• Here’s a link to the OFAC letter we mentioned last week disputing some of the charges made by the New York State Department of Financial Services against Standard Chartered Bank.
• A report by Reuters says that Iran is now trying to open up banks in Armenia to skirt U.S. sanctions.
• The New York Times reports that Iran’s best buddy Iraq is also helping Iran skirt financial sanctions, including letting the newly sanctioned Iraqi bank, Elaf Islamic Bank, participate in the daily auction of U.S. dollars for Iraqi dinars conducted by the Central Bank of Iraq. The Central Bank says it is permitting Elaf’s participation because it believes Elaf’s assertion that the U.S. is lying when it accuses Elaf of dealing with Iran.
• You can add the Royal Bank of Scotland and Commerzbank to the list of European banks being investigated by U.S. authorities for their dealings with Iran.
• The United Nations today accused Iran of violating UN sanctions by supplying arms to Syria.
• The Office of Foreign Assets Control (“OFAC”) issued yesterday a general license to allow tax-exempt NGOs to transfer up to $300,000 in the next 45 days for Iranian earthquake relief, provided that the funds do not transit blocked persons such as Bank Sepah et al. Banks that had not been previously blocked by name but which were blocked solely the recent E.O. 13599, which blocked all the remaining banks in Iran, can be used for transfers. Drop meet bucket; bucket meet drop.

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