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Financial Services Law Insights and Observations

OFAC designates sanctions evasion network connected to IRGC-QF

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

Financial Crimes

On December 8, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13224 against a sanctions evasion network for facilitating and concealing the sale and shipment of hundreds of millions of dollars’ worth of oil for Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). According to OFAC, the designated individual’s companies “established international sales contracts for Iranian oil with foreign purchasers, arranged shipments of oil, and helped launder the proceeds, obscuring the oil’s Iranian origin and the IRGC-QF’s interest in the sales.” The action supplements designations announced in May, which targeted an element of this network responsible for facilitating millions of dollars’ worth of Iranian oil sales for both the IRGC-QF and Hizballah, backed by senior levels of the Russian Federation government and state-run entities (covered by InfoBytes here). 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 unless authorized by a general or specific OFAC license or are otherwise exempt. OFAC further warned that “engaging in certain transactions with the individuals and entities designated today entails risk of secondary sanctions.”