Pub. 9 2018 Issue 4

Winter 2018 29 West Virginia Banker •Review policies and procedures, par- ticularly those that might have allowed the types of transactions in question •For non-U.S. subsidiaries of U.S. in- stitutions, terminate any transactions with Iran •Maintain an overall awareness that these actions by the Trump admin- istration might just be the tipping off point for further events that may greatly affect the country as a whole—well beyond financial trans- actions Secondary Sanctions Currently, the U.S. is the only country to withdraw from the Iran Deal, a fact that potentially complicates our relations with the remaining coun- tries involved in the JCPOA, due to what’s called secondary sanctions. Secondary sanctions come into play for cases in which the U.S., another country, and Iran were involved in business dealings prior to our with- drawal from the deal—and the other country continues those dealings with Iran. For example, if the U.S. conducted transactions with France and Iran involving goods and services used in the Iranian automotive indus- try—and France continues those transactions that the U.S. has now sanctioned—France could be sub- ject to secondary sanctions. These sanctions can lead to commercial and legal risks. What’s Next? That’s the million-dollar question. Unfortunately, the answer is “wait and see.” However, if this presidential administration continues on its current course, Iran sanctions could be just the beginning. In fact, relations with a huge petroleum supplier, Saudi Arabia, appear less than solid following the death of journalist Jamal Khashoggi. For now, it’s vital that financial insti- tutions and all other American busi- nesses remain solidly aware of how this action plays out. And of course, screen and re-screen all customers.  Amber Goodrich, compliance strategist for CSI Regulatory Compliance, has more than 10 years of financial industry experience. She is a Certified Regulatory Compliance Manager (CRCM) and Certified Bank Secrecy Act (BSA) Professional (CBAP). B A N K E R BORN TO BE A David Fletcher • dfletcher@bbky.com • 304-389-4431 Full Tilt Service combined with Powerful Products makes the Bankers’ Bank the leader of the pack. Contact David for all your Correspondent Banking needs. Motorcycle courtesy of