Following the government’s reinstatement of the full range of sanctions on Iran as of November 5, 2018, the Office of Foreign Assets Control of the US Department of the Treasury has announced the replacement of the List of Foreign Financial Institutions Subject to Part 561 with the List of Foreign Financial Institutions Subject to Correspondent Account of Payable-Through Account Sanctions (the CAPTA list). The Part 561 List contained the names of foreign financial institutions prohibited from opening or maintaining a correspondent or payable-through account in the US; the list also contained the specific conditions to be imposed on the institution. The institutions formerly listed on the Part 561 list have been moved to CAPTA. The prohibitions applicable to institutions on the CAPTA list include the Iranian Financial Sanctions Regulations, 31 C.F.R. Part 561, the Hizbollah International Financing Prevention Act of 2015, the Ukraine Freedom Support Act of 2014 as amended by the Countering America’s Adversaries Through Sanctions Act, and the North Korea Sanctions Regulations, 31 C.F.R. part 510.
March 14, 2019
OFAC decommissions the Part 561 List, moves institutions to CAPTA list
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