Under the Comprehensive Iran Sanctions, Accountability, and Divestiture Act (CISADA), what can OFAC do to foreign financial institutions that conduct significant transactions with sanctioned Iranian entities?
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A
Impose criminal penalties on their U.S. employees
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B
Cut them off from the U.S. financial system
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C
Require them to file SARs with FinCEN
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D
Seize their U.S.-based assets immediately without a court order