Client Alert

| August 26, 2010

Treasury Department Issues CISADA Implementing Regulations Regarding Financial Institutions and Activities

On August 16, 2010 (approximately 45 days before they were required to be issued), the Treasury Department's Office of Foreign Assets Control ("OFAC") published regulations implementing certain banking and financial sanctions provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act ("CISADA"), 75 Fed. Reg. 49836 (2010). The regulations issued are final and went into effect immediately, although OFAC is accepting comments on the regulations through October 15, 2010.

For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:

Harry L. Clark

+1 202 346 7980

Alan Wm. Wolff

+1 202 346 7800

Paul A. Howard

+1 202 346 7749

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383