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Financial Services Law Insights and Observations

OFAC sanctions Iranian leaders

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

Financial Crimes

On October 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13553 against 10 Iranian officials related to the ongoing crackdown on nationwide protests in Iran and internet censorship, as well as two Iranian intelligence actors and two Iranian entities involved in the Iranian government’s efforts to disrupt digital freedom. As previously covered by InfoBytes, on October 6, OFAC sanctioned seven senior leaders within Iran’s government and security apparatus for the shutdown of Iran’s internet access. OFAC also sanctioned Iran’s Morality Police along with seven senior leaders who oversee Iran’s security organizations (covered by InfoBytes here). According to OFAC, the recently announced sanctions “coupled with additional initiatives such as the release of Iran General License D-2, which expands and clarifies the range of U.S. software and internet services available to Iranians under OFAC’s sanctions program, demonstrate the United States’ commitment to support the Iranian people’s call for accountability and justice, as well as their right to freely exchange information, including online.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons must be blocked and reported to OFAC. U.S. persons are also prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, and “persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions,” OFAC said. Additionally, OFAC warned that “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today could be subject to U.S. correspondent or payable-through account sanctions.”