OFAC Iran Alert Warns Foreign Banks of Sanctions Risk, Not an Automatic U.S. Account Ban

OFAC Iran Alert Warns Foreign Banks of Sanctions Risk, Not an Automatic U.S. Account Ban The U.S. Treasury warned foreign financial institutions on October 5 that continued business with Iran or its financial sector could lead to sanctions. But the alert is a notice of risk, not an order cutting every bank off from the United States. The distinction matters: OFAC's amended FAQ 156 describes a separate finding and publication process for imposing restrictions on a particular bank's U.S. correspondent or payable-through accounts.

What changed: OFAC issued a dated warning to foreign banks on October 5, while pointing to existing and recently expanded sanctions powers. What did not change automat…