On October 25, 2019, the U.S. Financial Crimes Enforcement Network designated [3]Iran as a "jurisdiction of primary money laundering concern" under section 311 of the US Patriot Act [4]. According to a press release [5] from the Department of the Treasury, this means that "the opening or maintaining of a correspondent account in the United States for or on behalf of an Iranian financial institution" is prohibited. It also prevents "foreign financial institutions' correspondent accounts at covered U.S. financial institutions from processing transactions involving Iranian financial institutions." In recognition that this designation may impact the delivery of humanitarian aid to Iranian people, the U.S. Departments of the Treasury and State simultaneously announced the creation of a humanitarian mechanism aimed at "help[ing] the international community perform enhanced due diligence on humanitarian trade to ensure that funds associated with permissible trade in support of the Iranian people are not diverted by the Iranian regime to develop ballistic missiles, support terrorism, or finance other malign activities." The mechanism will, among other things, "enable foreign governments and foreign financial institutions to seek written confirmation from Treasury that the proposed financial channel will not be exposed to U.S. sanctions in exchange for foreign governments and financial institutions committing to provide to Treasury robust information on the use of this mechanism on a monthly basis." The mechanism's specific requirements [6] provide detail regarding transaction documentation and information that Treasury and State may require.