A FinCEN final rule imposing strict prohibitions on the access of Iranian financial institutions to the U.S. financial system was published in the Federal Register. The final rule will become effective on November 14, 2019.

As previously covered, in accordance with Section 311 of the USA PATRIOT Act, FinCEN designated Iran as a "jurisdiction of primary money laundering concern." Generally, the final rule prohibits anyone from (i) opening or maintaining accounts in the United States on behalf of Iranian financial institutions and (ii) processing transactions involving Iran's financial institutions.

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