Iran Sanctions: Plan now for imminent change


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Sanctions against Iran will be soon be lifted. Or will they? And does it even matter to you if you’re doing a good job with your OFAC lists?

The nuclear deal between Iran, the U.S., and other Western powers appears to have survived its biggest hurdles in the U.S. Senate. And that means some sanctions against Iran will be lifted very soon. But in a patchwork manner. And not the sanctions related to terror financing. And maybe none will be lifted by the U.S. if Senate Majority Leader Mitch McConnell succeeds in a new effort to maintain sanctions until Iran recognizes Israel’s right to exist.

Sanctions Changes: Plan today to manage the future

Confused yet? You should be. There are so many moving pieces to the sanctions machinery related to Iran that it would be easy for U.S. banks to just sit tight and wait for the OFAC lists and do business as usual. But Iran will be hotly pursuing new development deals, and financial institutions need to be ready for a complex sanctions environment. AML Partners CEO Frank Cummings urges financial institutions to embrace planning today to avoid problems in the future.

“There are many screening systems that have Iran completely blocked, so there are going to be massive system changes—and there are going to be mountains of false positives if this is not managed correctly,” Cummings said.

To get ahead of these problems, a little work now will save a ton of work later: “It’s best to prepare and review your systems now,” Cummings said. He suggested tasks like reviewing internal blocked lists and revalidating any licenses you have.

“If you sit back and do business as usual, be prepared for minor chaos,” he said. “This is truly an example of when you fail to plan, you’re planning to fail.”


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