CISADA (2010)

The Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, commonly called CISADA, is a United States statute that expanded energy, financial, procurement and human-rights measures concerning Iran. Section 104 established the best-known mechanism: restrictions on United States correspondent or payable-through accounts maintained for a foreign financial institution found to have knowingly engaged in specified Iran-related conduct.

Authority and procedure

CISADA amended the Iran Sanctions Act and directed Treasury to issue regulations concerning foreign financial institutions. The statutory and regulatory tests cover specified conduct, including facilitating significant transactions or providing significant financial services for designated Iranian financial institutions or the Islamic Revolutionary Guard Corps in the circumstances stated by law.

The consequence is not an automatic freeze of every foreign bank. Treasury may prohibit, or impose strict conditions on, opening or maintaining a correspondent or payable-through account in the United States for the foreign institution. The foreign institution, Iranian counterparty, United States correspondent bank and underlying customer occupy different legal positions. Knowledge, significance, applicable exceptions and the date of the transaction matter.

Treasury implements the mechanism through the Iranian Financial Sanctions Regulations, 31 C.F.R. part 561. United States financial institutions must follow any account prohibition or condition and applicable reporting obligations. A regulatory finding is an administrative sanctions action, not a criminal conviction of the foreign bank.

The regulations also contain definitions, exemptions, waivers and procedures that can alter the result for a particular transaction or institution.

Use and interaction with later law

On 31 July 2012, Treasury announced sanctions against Bank of Kunlun in China and Elaf Islamic Bank in Iraq under CISADA. Treasury stated that the institutions had facilitated significant transactions or provided significant financial services for designated Iranian banks. Elaf was removed from the relevant restriction in May 2013 after Treasury reported a change in conduct. These cases show that imposition and removal require separate official acts.

CISADA also expanded sanctions concerning Iran's petroleum sector, authorised specified divestment policies, added procurement restrictions and addressed technology associated with human-rights abuses. Later statutes, including section 1245 of the National Defense Authorization Act for Fiscal Year 2012, added related but separate measures concerning the Central Bank of Iran and petroleum transactions. They should not be attributed to CISADA alone.

Strategic significance and limits

Correspondent-account restrictions exploit foreign banks' need for access to United States clearing and customers. The threatened loss or constraint of that access can induce institutions to reduce Iran exposure before formal action, producing a Compliance cascade. It does not follow that every withdrawal was legally compelled by CISADA, or that the Act alone caused Iran's later economic or diplomatic decisions.

The mechanism's extraterritorial effects remain contested by affected states and firms. Current application must be checked against the amended statute, 31 C.F.R. part 561, waivers, exceptions and programme guidance.

See also

US secondary banking and oil sanctions against Iran under CISADA and NDAA (2010-2012) · NDAA FY2012 Section 1245 (2011) · United States-led financial pressure campaign against Iran (2006-2015) · Secondary sanctions · Compliance cascade · Chokepoint effect

Sources

1. Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, Pub. L. 111-195, 124 Stat. 1312, 1 July 2010.
2. Department of the Treasury, Iranian Financial Sanctions Regulations, 31 C.F.R. part 561, checked 30 July 2026.
3. Department of the Treasury, Treasury sanctions Kunlun Bank in China and Elaf Islamic Bank in Iraq, 31 July 2012.
4. Department of the Treasury, Treasury removes sanctions on Iraqi bank, 17 May 2013.
5. Office of Foreign Assets Control, Iran sanctions, checked 30 July 2026.