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OFAC Provides Additional Iran Sanctions Guidance
14 June 2016
View Client Update
OFAC has clarified the scope of what U.S. companies may do in regard to Iran.
U.S. banks may operate correspondent accounts for third-country banks that deal with Iran but may not process Iran-related transactions.
U.S. companies may allow their foreign subsidiaries to establish a physical presence in Iran.
Non-U.S. companies should adopt policies excluding U.S. directors and management from participating in Iran-related transactions.
A company owned 50% or more by U.S. persons is treated as U.S.-owned, except for publicly traded companies with diffuse ownership.
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