With this E.O, in 2013, the US Treasury Department designated an exchange house and a trading company for allegedly helping Iranian attempts to circumvent sanctions. Al Hilal Exchange and Al Fida International General Trading, based in Dubai, were designated for providing financial services to previously designated Iranian banks, including Bank Mellat which had been directly involved with the Iranian nuclear program. It appeared that Iran had turned increasingly to exchange houses and trading companies in its attempts to evade international sanctions and maintain its access to foreign exchange and earlier in 2013, Treasury had warned the financial community about the risks posed by Iran’s use of exchange houses and trading companies to evade sanctions in a circular.

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