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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
Related Topics:
Office of Foreign Assets Control
Attachment:
Iranian Transactions Regulations Amended
https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information/actions/20081110.shtml
Contact:
Anti-Money Laundering Specialist Marie Edwards
at SASFIL@FDIC.gov or (202) 898-3673
Note:
FDIC Financial Institution Letters (FILs) may be
accessed from the FDIC's Web site at
http://www.fdic.gov/news/news/financial/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).
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