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Financial Services Law Insights and Observations

OFAC sanctions individuals and entities connected to IRGC-QF

Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC OFAC Sanctions OFAC Designations SDN List Privacy, Cyber Risk & Data Security Iran

Financial Crimes

On September 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions as part of a joint action with the DOJ, Department of State, FBI, U.S. Cyber Command, National Security Agency, and Cybersecurity and Infrastructure Security Agency, against ten individuals and two entities for their roles in conducting malicious cyber acts, including ransomware activity. The individuals and entities designated are affiliated with Iran’s Islamic Revolutionary Guard Corps (IRGC), which “is known to exploit software vulnerabilities in order to carry out their ransomware activities, as well as engage in unauthorized computer access, data exfiltration, and other malicious cyber activities.” OFAC also noted that a joint cyber security advisory was published to highlight continued malicious cyber activity by advanced persistent threat actors that the authoring agencies assess are affiliated with IRGC. As a result of the sanctions, 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 additional sanctions.