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Financial Services Law Insights and Observations

OFAC sanctions Iranian tech company and employees

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

Financial Crimes

On June 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13846, against an Iran-based technology company, two senior employees, and an affiliate based in the UAE. According to OFAC, the sanctioned persons and entities partook in facilitating the Iranian regime’s censorship of the internet in Iran. The technology company is a key partner in Iran’s development of the National Information Network, which, OFAC states is, “a countrywide intranet that is being used to disconnect the Iranian people from the global internet.” As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Additionally, OFAC warned that “persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action.” Also, OFAC noted that unless an exception applies, any foreign financial institution that knowingly takes part in a significant transaction or provides significant financial services for any of the persons designated could also be subject to U.S. sanctions.

In conjunction with the sanctions, OFAC issued several Iran-related general licenses (see General License P).