Clifford Chance

CISADA Update: Proposed Reporting Requirements

3 May 2011

On May 2, 2011, the US Treasury Department ("US Treasury") published a proposal for implementing the US correspondent account provision of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA"). The proposal would 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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