Iranian American Organizations Contact Bank of America Regarding Suspensions of Iranian Accounts

May 23, 2014, Washington, D.C. – Today, the Public Affairs Alliance of Iranian Americans (PAAIA), along with several other Iranian American organizations, sent a letter to Bank of America in response to recent reports of Iranian students or Iranian Americans whose Bank of America accounts have been suspended or terminated. In particular, PAAIA has heard that suspensions have most recently occurred to a number of Iranian students at Virginia Polytechnic Institute and State University without any explanation or prior notice.

“We are concerned that Bank of America, in an attempt to comply with U.S. economic sanctions targeting Iran, may be unjustly suspending or closing accounts without conducting necessary reviews of the accounts beforehand,” states the letter. “We are furthermore concerned that the bank is not providing a fair review of the suspensions once they do occur. We are aware of several individuals who have provided documents to the bank which have ultimately resulted in re-opening of accounts, but only after days of unjust suffering and anxiety about access to needed funds, their checks pending, and multiple attempts to speak with a representative.”

The letter explains that according to the Iranian Transactions and Sanctions Regulations (ITSR), once these students arrive in the United States, they are considered to be U.S. persons, the definition of which includes an individual physically present in the United States. As such, the maintenance of an account by a U.S. financial institution on behalf of an Iranian student residing in the United States on a student visa is not a prohibited exportation of services to Iran, but rather a provision of services to a U.S. person. Furthermore, the ITSR allow for a number of transactions related to personal and family remittances that originate from Iran, licenses for which specifically impact Iranian Americans who have family in, or are receiving inheritances from Iran.

The letter recommends proper and secondary review of customer accounts before taking measures as drastic as suspending or closing bank accounts and the implementation. “Such heightened internal scrutiny will help ensure that bank actions do not violate either the spirit or letters of any federal regulations and do not jeopardize the financial status of its customers,” write the authors. “In the case of the Iranian students whose bank accounts have been suspended in Virginia, this additional scrutiny ensures that these young people are not unduly burdened and that their academic status is not adversely impacted.”

In addition, the letter recommends the implementation of a uniform policy, where individuals whose accounts have been suspended are guided to the appropriate individual who can immediately handle the review of further documents and work to resolve the situation, while keeping the customer informed and reassured that all will be done to solve the problem.

PAAIA will continue to follow this issue and other incidents that impact the welfare of our community and will take appropriate action as needed.

Click here to read the full letter.

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