“‘There are so many sanctions and they are so complex and they cover so many entities in Iran, especially in the financial sector, it’s very difficult to find legal, viable, credible, efficient business counterparts in Iran for international businesses to do business with,’ says Elizabeth Rosenberg, a former Treasury Department sanctions official.

“Even if Western companies do find Iranian business and banking counterparts, Rosenberg says, there’s no telling what can happen along the supply chain. ‘Now most of the big [Iranian] banks are designated [for sanctions], and as you can imagine, any smaller bank doesn’t have as much capital on hand, they may have less capacity to handle cross-border financial transactions, and they may also not have in place some of the appropriate controls for safety and soundness or anti-money-laundering controls.’

“‘What’s different [with this round of sanctions] is that the U.S. has reimposed the sanctions it lifted pursuant to the nuclear deal and it has layered on many more, including doing things like designating some Iranian financial institutions not previously designated and that were previously used to facilitate food, medicine and medical imports,’ says Rosenberg…”

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