OFAC sanctions international network involved in procuring materials for Iranian nuclear program

Financial Crimes Department of Treasury OFAC Sanctions Iran Of Interest to Non-US Persons

On July 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13382 against an international network of seven entities and five individuals involved in the procurement of sensitive materials for sanctioned elements of Iran’s nuclear program. According to OFAC, the network—based in Iran, China, and Belgium—acted as a procurement network in order to acquire materials controlled by the Nuclear Suppliers Group (NSG), which were then used in facilities belonging to the Atomic Energy Organization of Iran. OFAC noted that while United Nations Security Council Resolution 2231 does permit certain NSG-controlled items to go to Iran, participants are required to receive advance, case-by-case approval, which the identified entities and individuals in this action did not receive. As a result of the sanctions, “all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated entities and individuals. Moreover, OFAC warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated entities and individuals, they may be subject to U.S. correspondent account or payable-through account sanctions which, if imposed, could restrict their access to the U.S. financial system.