Examining OFAC Guidance On NDAA Iran Sanctions

Law360, New York (March 5, 2012, 1:41 PM EST) -- On Feb. 14, 2012, the U.S. Treasury Department's Office of Foreign Assets Control released guidance, in the form of frequently asked questions, relating to Section 1245 of the National Defense Authorization Act of 2012. Section 1245 of the NDAA enacts additional sanctions intended to isolate Iran further from the global economy.[1] The act:

Requires the president to prohibit the opening of, and prohibit or impose “strict conditions” on the maintenance of, U.S. correspondent or payable-through accounts of “foreign financial institutions” where such institutions are determined “knowingly”...
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