A bill was recently introduced by U.S. Representative Bryan Steil (R-Wisconsin) that would allow the U.S. Treasury Department to target European financial intuitions conducting business with Iran through the Instrument in Support of Trade Exchanges (INSTEX) vehicle in order to avoid U.S. sanctions.
While there have been a low number of actions against European institutions, I recently explained to Payments Compliance that “arguably that is because many major non-U.S. financial institutions, particularly in Europe, have decided to halt business with Iran and thereby have eliminated the U.S. government’s basis for potentially imposing secondary sanctions. But I also think that the limited use of secondary sanctions against non-U.S. financial institutions is in part because even this U.S. administration understands that imposing secondary sanctions against major non-U.S. banks is a very significant step.”
Check out the full article, “U.S. Lawmaker Launches Legislative Assault on INSTEX.” It was published on March 4 and is available online (subscription required).