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US sanctions Iran-linked banks and Cuba’s BICSA

The US Treasury added 27 people and entities under Iran and Cuba sanctions programmes on 15 October. The list includes Baghdad-based IDB and Cuba’s state-owned BICSA. Washington alleges that the Iran-linked network facilitated funds for Tehran. Separate arrangements set 30 October and 14 November deadlines for ending bank dealings, with different permissions for US and foreign persons.

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A US flag above the columned Treasury building and granite steps in autumn daylight.

Iran-linked financial institutions join the list

The US Treasury imposed sanctions on 27 people and entities under its Iran and Cuba programmes on 15 October. Its Office of Foreign Assets Control (OFAC), which administers US sanctions, listed 16 individuals and 10 entities under Iran-related Executive Order 13902. Cuba’s state-owned Banco Internacional de Comercio, known as BICSA, was separately designated under Executive Order 14404. The Iran-related list includes Baghdad-based International Development Bank for Investment and Finance, also known as Iraq Development Bank (IDB).[1], [2]

Treasury alleged that IDB facilitated dollar transactions for Iran and had links to Iran-aligned armed groups. It also listed Iran’s Chabahar International Bank Overseas Company and Jazireh International Bank Company, describing them as offshore structures connected to Bank Shahr and Bank Mellat respectively. The action targeted Sayyed Ruhollah Razavi and associated companies over alleged transfers of petroleum revenue.[1]

IDB wind-down licence runs through 30 October

Property within US jurisdiction is blocked and transactions by US persons are generally prohibited. OFAC issued General License FF alongside the designations. It permits transactions ordinarily necessary to wind down dealings with IDB through 30 October, including entities the bank owns directly or indirectly by at least 50 per cent. Payments to blocked persons must enter blocked accounts. Dealings involving other blocked persons remain outside this permission unless separately authorized. All 16 individuals and eight of the 10 Iran-related entities were marked as subject to secondary sanctions.[1], [2]

BICSA guidance distinguishes foreign and US persons

BICSA has a different wind-down arrangement. OFAC’s FAQ 1276 describes a limited policy of not targeting foreign persons for specified transactions necessary to end dealings with the bank or entities it owns by at least 50 per cent, through 14 November. Persons subject to US jurisdiction remain prohibited from transacting with BICSA. They also need separate authorization to participate in a foreign customer’s wind-down. Foreign persons can still face sanctions risk if assets are returned to a sanctioned party or moved elsewhere for its potential use.[1], [2]

For more information on this topic, you can read the related columns.

References

  1. News sourceUS Department of the TreasuryUS sanctions Iran-linked financial network and Cuban bank↩1↩2↩3↩4
  2. News sourceSanctions.comUS adds 27 people and entities under Iran and Cuba sanctions↩1↩2↩3
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