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Financial Services Law Insights and Observations

OFAC sanctions entities connected to IRGC-QF

Financial Crimes OFAC Department of Treasury Of Interest to Non-US Persons SDN List OFAC Sanctions OFAC Designations

Financial Crimes

On May 25, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against an international oil smuggling and money laundering network led by the  Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). According to OFAC, the designated network, “has acted as a critical element of Iran’s oil revenue generation, as well as its support for proxy militant groups that continue to perpetuate conflict and suffering throughout the region.” As a result, all property, and interests in property of the designated individuals and entities, “and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons, must be blocked and reported to OFAC.” U.S. persons are generally prohibited from engaging in transactions with the designated persons. OFAC further warned that “engaging in certain transactions with the individuals and entities designated today entails risk of secondary sanctions.”