The Trump administration has sounded the death knell for humanitarian trade with Iran. By designating Iran a jurisdiction of primary money laundering concern and imposing additional restrictions on foreign banks maintaining accounts for Iranian financial institutions, the United States Department of the Treasury has imposed a prohibitive bar for parties seeking to facilitate humanitarian trade with Iran—one that will further put the squeeze on the Iranian people and limit their access to food and critical medicines.
By designating Iran a jurisdiction of primary money laundering concern, Treasury finalized a rule requiring U.S. banks to conduct “special due diligence” on accounts maintained on behalf of foreign banks if those foreign banks themselves maintain accounts for Iranian financial institutions. The practical consequence is that U.S. banks will urge their foreign correspondents to terminate any accounts maintained on behalf of Iranian banks so as to eliminate sanctions risk and mitigate the need to apply additional resources to monitor their foreign correspondents. This will further sever Iran from the global financial system, as Iran’s few non-designated banks find it increasingly difficult to maintain accounts abroad.