On August 16, 2010, the U.S. Department of the Treasury issued, with immediate effect, the Iranian Financial Sanctions Regulations (the “Regulations” or “IFSR” – 31 CFR 561) to implement subsections 104(c) and 104(d) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”). Please see our previous memorandum for a discussion of CISADA. Although the Regulations do not require notice of proposed rulemaking, the Office of Foreign Assets Control (“OFAC”) will accept comments on the final rule. OFAC is not required to respond to the comments or to amend or republish the final rule. Comments may be submitted on or before October 15, 2010. All comments received will become available to the public.