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Financial Services Law Insights and Observations

OFAC sanctions Iranian officials

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

Financial Crimes

On November 23, the U.S. Treasury Department Office of Foreign Assets Control (OFAC)) announced sanctions pursuant to Executive Order 13553 against three Iranian security officials related to the Iranian regime’s continued crackdown on ongoing protests throughout the country, including most recently in Kurdish areas. According to OFAC, the Iranian regime has increased its aggressive actions against the Iranian people as part of its ongoing suppression of peaceful protests against a regime that denies human rights and fundamental freedoms to its people. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the individuals designated today may themselves be exposed to designation. Additionally, OFAC warned that “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.”