Highlights:

• Effective November 10, 2008, OFAC will no longer allow U.S. depository institutions to process "U-Turn" transfers under the ITR.
• A "U-turn" transfer consists of:
  (1) Initiating a dollar-denominated transaction offshore by order of a foreign bank's customer;
  (2) Transferring the dollar-denominated amount from a correspondent account held by a domestic bank for the foreign bank to a correspondent account held by another domestic bank for a different foreign bank; and
  (3) Ultimately transferring the funds offshore as a dollar- denominated account of the second foreign bank's customer.
• Prohibiting "U-Turn" transfers eliminates the financial benefit to Iranian banks or other persons in Iran or the Government of Iran.
• This amendment does not revoke existing authorizations under the ITR for transactions relating to humanitarian aid and other legitimate activities.
• OFAC information is available at https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information .
• If you have questions, please call OFAC's Compliance Programs Division at 1-800-540-6322.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
BSA Compliance Officer

Note:
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at http://www.fdic.gov/news/financial-institution-letters/2008/index.html .

To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html .

Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, Room E 1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).