As you may know, OFAC finally designated Bank Tejarat last week. This bank was already identified as a Government of Iran (GOI) entity but not it is officially designated and attempted wires from or through the U.S. will be blocked.  The European Union took a similar step as well.  This is particularly critical for Europe, as Bank Tejarat was by some accounts the last Iranian government bank that could work directly with European banks. Outside of this designation, not much else appears to have changed with respect to US-Iran transactions.

So where does that bring us?  It all depends on what the next step is with Iran. Will Iran come to an agreement over its nuclear energy file? Or will it continue to defy UN Security Council Resolutions?

The collapse of the Iranian Rial in recent weeks and internal issues may cause Iran to reach some compromise with the P5+1 states over the nuclear file. If that were to happen, would sanctions be instantaneously lifted? Probably not, although certain restrictions would gradually be removed, others most likely much later. It will take time however for banks to resume business with their Iranian counterparts, though companies wishing to earn hefty profits may want to avail themselves of the Iranian market before their competitors.

Many may be worried that any specific licenses obtained by OFAC may quickly become useless given the tightening sanctions on Iran. That said, there is little reason to believe that an OFAC license would be voided by a new law. If anything, one could argue that the bigger fear (if any) is a restriction by Iran to limit the outflow of hard currency.  Interestingly enough, reports have been abounding that larger goods in Iran are being priced in Dollars (presumably with the expectation that the exchange rate at the day of the transaction be used to determine the value of the transactions in Rials.

It is certainly hard to predict the trajectory of these transactions.  A total ban by the EU seems inconceivable, and there is little else the United States has among its options with respect to sanctioning. Should Iran return to the negotiation table and any serious agreement is reached, we may be able to expect the sanctions vise gripping Iran to loosen upon a bit.