Here is @FDD trafficking in disinformation.

This is dead wrong on multiple counts. Let me explain why.
Section 104 of CISADA, which sanctions banks that engage in certain Iran-related transactions, does not contain a humanitarian exception.

Foreign banks that transact with designated Iranian banks risk sanctions, regardless of the nature of the transaction.
That is why, for instance, @FDD has advocated designating all of Iran's banks under US sanctions authorities.

Because it renders *all* dealings with them sanctionable.

Including humanitarian transactions.
OFAC has codified these sanctions at 31 C.F.R. § 561.201.

OFAC has not set forth any license or other exception that would render humanitarian transactions non-sanctionable under § 561.201.
Iran's central bank was already on OFAC's SDN List. But @FDD pushed for its designation under E.O. 13224 regardless.

The sole effect of this move was to nullify the humanitarian exception at § 1245 of the 2012 NDAA.
@FDD also advocates for designating Iran's *entire financial sector* under Executive Order 13902.

The effect of that would be to kill humanitarian trade.

There is no humanitarian exception under E.O. 13902.
Does @FDD_CEFP's @ELforeignpolicy stand by this...?

Is there any shame at all...?
People in Iran will die because of @FDD's disinformation.
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