4/7/2024 0 Comments Irc 174![]() The Iranian Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in determining what is significant (as it relates to transactions) in 31 C.F.R § 561.404, which allows the Secretary of the Treasury to consider the “totality of the facts and circumstances” while providing a list of seven broad factors that can play a role in the determination, including: (1) the size, number, and frequency of transactions (2) the nature of the transaction(s) (3) the level of awareness of management and whether the transaction(s) are part of a pattern of conduct (4) the nexus between the transaction(s) and a blocked person (5) the impact of the transaction(s) on statutory objectives (6) whether the transaction(s) involve deceptive practices and (7) such other factors that the Secretary deems relevant on a case-by-case basis.
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