FINTRAC guidance related to the Ministerial Directive on Financial Transactions Associated with the Islamic Republic of Iran issued on July 25, 2020

[TaylorWarden]

https://www.fintrac-canafe.gc.ca/obligations/dir-iri-eng

I will not quote the entire MD here but just say that FINTRAC and the FATF are still encouraging the due diligence of reporting entities for transactions which involve Iran.  The most pertient information about this guidance is:

·         electronic funds transfers, remittances or transfers (EFTs) that include an Iranian originating or destination address which may include transactions where the ordering person or entity, beneficiary, or third party details are Iranian;

·         the transactions made by representatives of the Government of Iran (for example, transactions on an Embassy of Iran's bank account in Canada).

Please discuss.