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Financial Services Law Insights and Observations

OFAC sanctions Iranian officials

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

Financial Crimes

On December 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13553 against the prosecutor general and key military and paramilitary officials in Iran, as well as a company manufacturing and providing Iran’s Law Enforcement Forces with anti-riot equipment. According to OFAC, the designations target the senior official overseeing the prosecution of protestors, as well as leaders of military and paramilitary organizations accused of violently cracking down and detaining protestors, and a company that procures and provides security forces with tools of suppression. 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.”