Highlights:

• Effective November 10, 2008, OFAC will no longer allow U.S. depository institutions to process "U-Turn" transfers under the ITR.
• A "U-turn" transfer consists of:
  (1) Initiating a dollar-denominated transaction offshore by order of a foreign bank's customer;
  (2) Transferring the dollar-denominated amount from a correspondent account held by a domestic bank for the foreign bank to a correspondent account held by another domestic bank for a different foreign bank; and
  (3) Ultimately transferring the funds offshore as a dollar- denominated account of the second foreign bank's customer.
• Prohibiting "U-Turn" transfers eliminates the financial benefit to Iranian banks or other persons in Iran or the Government of Iran.
• This amendment does not revoke existing authorizations under the ITR for transactions relating to humanitarian aid and other legitimate activities.
• OFAC information is available at http://www.treas.gov/offices/enforcement/ofac.
• If you have questions, please call OFAC's Compliance Programs Division at 1-800-540-6322.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
BSA Compliance Officer

Related Topics:
Office of Foreign Assets Control

Attachment:
Iranian Transactions Regulations Amended
http://www.treas.gov/offices/enforcement/ofac/actions/20081110.shtml

Contact:
Anti-Money Laundering Specialist Marie Edwards
at SASFIL@FDIC.gov or (202) 898-3673

Printable Format:
FIL-140-2008 - PDF (PDF Help)

Note:
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at http://www.fdic.gov/news/news/financial/2008/index.html.

To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html.

Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, Room E 1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).