Financial Sector Continuing Sanctions
Primary and secondary sanctions on Iranian financial institutions could continue to make it difficult for Iran to re-integrate fully into the global financial markets. U.S. Treasury Department officials have testified that Iran will not have access to the American financial system, that non-nuclear-related sanctions will remain in place affecting some banks, and that secondary sanctions will also remain in place.
Two Iranian banks remain formally sanctioned and tagged (click here for explanation) by the U.S. Treasury Department:
Five other Iranian banks were explicitly sanctioned for providing support to the IRGC and/or the Qods Force, although their Treasury designations do not include the IRGC or SDGT tags. These banks should be subject to primary and secondary sanctions, but whether or not they are will remain unclear until Treasury issues its revised guidance.
Bank Melli and its subsidiaries:
Melli Bank PLC
Mir Business Bank (fka Bank Melli ZAO)
Bank Sepah, which is the IRGC's financial institution.
Post Bank of Iran (" Designated under E.O.13382 for providing services to Bank Sepah"--U.S. Treasury Department Fact Sheet)
Europaische-Iranische Handelsbank (EIH) (for providing services to Bank Sepah--U.S. Treasury Department Fact Sheet)
Ansar Bank (" Designated under E.O.13382 for providing services to the Islamic Revolutionary Guard Corps (IRGC). "--U.S. Treasury Department Fact Sheet). Ansar Bank is also partly owned by Bonyad Taavon Sepah.