Quoted: “Protections already exist for humanitarian trade,” but this “has a major chilling effect on any financial entities considering doing business with Iran.
This action would turn Iran’s financial sector radioactive.” bloomberg.com/news/articles/…
Note: humanitarian transactions take place through the central bank of Iran thanks to General License No. 8 and not through these 14-16 banks. OFAC also gives comfort letters to foreign banks and a Swiss channel exists to facilitate this trade: sanctionsnews.bakermckenzie.com/ofac-issues-ne…
The blacklisting of the financial sector is a logical extension of the FinCEN 311 finding and the reimposition of countermeasures by FATF. The entire financial sector supports regime’s illicit activities.
Part of sanctions wall of market & political deterrence to persuade companies & banks to stay out of Iran.
This will important if Biden wrongly returns to the JCPOA and tries to fill regime’s coffers with tens of billions of dollars to finance its destructive activities.
And, of course, the unsanctioned trade still taking place does make a difference to Iran’s economy: “Iran has continued to do business with several countries including China and the United Arab Emirates, with total non-oil foreign trade reaching $24.6 billion in March-August.”
For more explanation, see my @WSJopinion oped co-authored with @FDD @rich_goldberg here: wsj.com/articles/how-t…
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