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Here is @FDD trafficking in disinformation.
This is dead wrong on multiple counts. Let me explain why.
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.
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& #39;s banks under US sanctions authorities.
Because it renders *all* dealings with them sanctionable.
Including humanitarian transactions.
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.
OFAC has not set forth any license or other exception that would render humanitarian transactions non-sanctionable under § 561.201.
Iran& #39;s central bank was already on OFAC& #39;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.
The sole effect of this move was to nullify the humanitarian exception at § 1245 of the 2012 NDAA.
