are ways to carry out an OFAC SDN List removal. As of early 2008, the targeted banks, such as Bank Mellat, had been able to replace banking relationships with a few large sanction-compliant banks with relationships with a larger number of smaller non-compliant banks. In 2008, the United States Department of the Treasury ordered Citigroup Inc. to freeze over $2 billion held for Iran in Citigroup accounts. For individuals and small businesses, these banking restrictions have created a large opportunity for the hawala market, which allows Iranians to transfer money to and from foreign countries using an underground unregulated exchange system. In June 2010, in the case United States v. Banki, the use of the hawala method of currency transfer led to a criminal conviction against a U.S. citizen of Iranian origin. Banki was sentenced to two and a half years in federal prison; however, on the sentencing guidelines, this type of offense could result in imprisonment of up to 20 years. Obama presidency On June 24, 2010, the United States Senate and House of Representatives passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), signed into law by President Obama on July 1, 2010. The CISADA greatly enhanced restrictions on Iran, including the rescission of the authorization for Iranian-origin imports for articles such as rugs, pistachios, and caviar. In response, President Obama issued in September 2010 and in May 2011, and in November 2011. The sanctions imposed on Iran at the beginning of 2012 "had persistent and significant effects on the Iranian economy. The cost reached its maximum of 19.1% of real gross domestic product 4 years after the application of the sanctions, and the economy has not fully recovered after their removal." On 31 July 2013, members of the United States House of Representatives voted 400 to 20 in favor of toughened sanctions. The United States imposed additional financial sanctions against Iran, effective 1 July 2013. An administration official explained that according to the new Executive Order "significant transactions in the rial will expose anyone to sanctions," and predicted “it should cause banks and exchanges to dump their rial holdings.” This took place as Iran's president-elect Hassan Rouhani was scheduled to take office on August 3, 2013. Sanctions against third parties In 2014, U.S. authorities put a $5 million bounty on Chinese businessman Li Fangwei, whom they alleged to have been instrumental in evading sanctions