Should this occur, the question arises as to the effect upon financial institutions who are located in those countries that are the primary means through which the sanctioned Iranian banks operate:

• The United Arab Emirates

• Bahrain

• Austria

Compliance officers at international banks in those nations, and compliance officers at financial institutions whose clients deal in international financial commerce with the above three, should closely monitor unfolding developments, lest they find their banks with pending funds transfers, letters of credit, or other large uncompleted transactions, when sanctions are announced. It would be wise to brief senior management on the issues at this time, to consult bank counsel, and to create a checklist of actions to be taken if and when the Central Bank is sanctioned, as even indirect transactions may expose your bank to US sanctions, or even criminal penalties, once sanctions are implemented.