Clifford Chance

CISADA Update: Reporting Requirements

6 October 2011

On October 5, 2011, the US Treasury Department issued a final rule implementing the US correspondent account provision of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA"). The final rule only lightly modifies the May 2, 2011 draft proposal issued by US Treasury, and will take effect immediately upon publication in the Federal Register. Consistent with the May 2 draft, the final rule will substantially increase US Treasury's extraterritorial ability to access and respond to information regarding the Iran-related activity of non-US banks that maintain US correspondent accounts.

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