NEWSLETTER-2019-metin

389 MISCELLANEOUS between a foreign financial institution and Iran are significant enough, that foreign financial institution risks being designated pursuant to one of the legal authorities authorizing the use of secondary sanctions. As of this time, secondary sanctions have applied only to Iran, though that can and may change. Outcomes of Violating Secondary Sanctions The aim of secondary sanctions is to put pressure on non-US persons to comply with US sanctions by threatening to cut them off from access to the US financial system. Therefore, once designated, secondary sanctions can prohibit US persons from doing business with that foreign third party, or require US banks to limit, or restrict, that foreign third party’s correspondent accounts in the US. Under secondary sanctions, the US can place the offending non- US person on either the SDN list or the Foreign Sanctions Evaders (FSE) list. In either case, once listed, US persons are prohibited from doing business with the sanctioned non-US person. The possible consequences of a person or organization entering the OFAC’s SDN list are summarized as follows: • The assets of real and legal persons listed in the US jurisdic- tion are blocked; • US persons may not conduct transactions with persons on the SDN list, as well as with legal entities that they control or hold more than 50% shares, either directly or indirectly; and • Internationally operating companies and international or lo- cal financial institutions in third countries outside the United States must also refrain from engaging in business relations- hips with those on the SDN list. Conclusion In late 2018, the US announced that their participation in the Joint Comprehensive Plan of Action (JCPOA) would end and, following a wind-down period, they would begin the re-imposition of sanctions