Secretary Kimmitt specifically cautioned financial institutions concerning possible efforts by Bank Sepah and Bank Sepah International, and added:

"In the coming days, we also urge states and financial institutions to be particularly vigilant and prevent efforts by Sepah to move assets, including to other Iranian state-owned institutions, or otherwise evade sanctions".

In the United States, financial institutions have a responsibility to ensure that they do not allow their correspondent banks to facilitate "nesting," a prohibited technique whereby sanctioned banks such as Sepah utilise the services of a foreign bank with a US correspondent account to covertly move funds into or through the American financial structure, without the knowledge or permission of the US bank.  

Whilst there have been no reported incidents, MLROs and compliance officers should anticipate that these sanctioned banks will attempt to avoid or evade the US & UN sanctions, and alert their staff to look for unusually large funds tranfers or commercial trade payment activity from Middle East entities or institutions which could have originated from sanctioned Iranian banks.