What's on the New Iran Sanctions List?

On Friday, January 12, US President Donald Trump waived — for now — nuclear-related sanctions against Iran. At the same time, he issued new sanctions against 14 people and entities in Iran, and Iran’s judiciary chief Sadegh Larijani appears at the top of the list. An Iranian government spokesman described the sanctions against Larijani as a “hostile action” and Iran’s foreign ministry said the move “crossed all red lines of conduct in the international community, is a violation of international law and will surely be answered by a serious reaction from the Islamic Republic.”

But this is not a new situation for Larijani. In March 2012, the European Union imposed sanctions on Larijani and 16 other Iranian officials, accusing him of playing a key role in serious human rights violations. And in recent days there were reports that Mahmoud Hashemi Shahroudi, his predecessor as judiciary chief, might join him on the EU sanctions list. Shahroudi was in Germany for medical treatment; but German authorities announced that he was under investigation for “crimes against humanity,” and by January 12 he had hastily returned to Tehran.

A new entry on the list is Morteza Razavi, president of Malaysia-based Green Wave Telecommunication and commercial director of Fanamoj, which is affiliated with Iran’s Revolutionary Guards (IRGC). The company first appeared on the US sanctions list in October 2017. Fanamoj is active in telecommunications and satellite technology and has been accused of providing the Revolutionary Guards (IRGC) with parts for its missile program.

Another name on the list is Gholamreza Ziaei, director of the notorious Rajaei Shahr Prison in Karaj near Tehran. He is well known to human rights organizations and, of course, to political prisoners who have spent time in his custody. One of them was the journalist Saeed Razavi Faghih who, in an interview with IranWire in November 2016 [Persian link], talked about the hellish conditions in the prison, including “poor nutrition, unsanitary environment, lack of medical facilities and the ill-treatment of prisoners by the medical staff, unreasonable disciplinary measures, easy availability of illegal drugs, fights among prisoners that sometimes lead to serious injuries and even the deaths, and sexual abuse of some prisoners.”

The US government has cited the same issues for including Ziaei on its sanctions list. “Rajaei Shahr Prison has denied prisoners adequate medical care and access to legal representation,” says the US Treasury press release. “Many Iranians who recently protested against their government are imprisoned at Rajaei Shahr, a facility where prisoners participating in hunger strikes are denied medical care; where there are reported incidents of sexual abuse and unlawful executions; and where at least one prisoner had his eye gouged out by prison officials.”

The European Union had earlier put the name of Hassan Akharian, head of Rajaei Shahr’s Ward 1, on its sanctions list.

Also new on the list is the Supreme Council of Cyberspace. This body was created in 2012, by order of Supreme Leader Ayatollah Khamenei, to centralize and oversee the government’s policymaking and regulation of the internet. Although the council is not the main authority that decides what should filtered, it plays a facilitating role in blocking social networks and web content. When recent nationwide protests started, it was this body that ordered Telegram to be blocked. The judiciary usually decides what to filter.

The most important members of this council are the president of the Islamic Republic, the speaker of parliament, the judiciary chief, the commander of the Revolutionary Guards, the commander of the national police, the president of Islamic Republic of Iran Broadcasting (IRIB), and seven members of the cabinet: the ministers for science, intelligence, education, defense, communications and technology, the Ministry for Islamic Culture and Guidance, and the Vice President for Science and Technology.

The addition of this council to the sanctions lists puts President Rouhani in an interesting situation. As president of the Islamic Republic he is not on the sanctions list, but as head of the Supreme Council of Cyberspace his activities fall under the new US sanctions.

The National Cyberspace Center, also new to the list, is controlled by the Supreme Council of Cyberspace. The council’s secretary, Abolhasan Firoozabadi, is both the director of this center and the Deputy Labor Minister. The center has the task of drawing up a five-year plan for developing cyberspace, cyber surveillance and “anticipating cyber attacks and defending vital infrastructure against such attacks.”

A similar organization that has also been added to the sanctions list is the Islamic Revolutionary Guard Corps' Electronic Warfare and Cyber Defense Organization. Although the US government’s announcement lists this as a separate entity, the Revolutionary Guards’ various cyber units appear to be intertwined and it is not entirely clear which entities are exactly targeted by the new sanctions.

The IRGC's first major foray into Internet activities started in 2007; from 2014, its activities came under the purview of the Revolutionary Guards Cyber Security Command. According to a 2008 report by the US research firm Defense Tech, the IRGC cyber army consisted of 2,400 full-time employees, and could leverage another 1,200 private hackers. No doubt its strength has grown substantially since then. Its annual budget is estimated at $76 million – but this reflects only part of the Revolutionary Guards’ cyber operations. In recent months there have been reports that that the IRGC is now using companies and individuals outside Iran, with nominally no relations with the Guards, to launch cyber attacks.

Iran Aircraft Industries (SAHA) is an important state-owned company that has now been placed on the sanctions list. This company was founded 51 years ago but it was taken over by the Iranian Defense Ministry after the 1979 Islamic Revolution. SAHA provides key maintenance and overhaul services for Iran's military helicopters and aircraft.

Next to SAHA on the list appears the Helicopter Support and Renewal Company (PANHA). According to the US Treasury, PANHA is a “leading Iranian helicopter maintenance and manufacturer, and has built and overhauled helicopters, including models manufactured in the United States, for the Iranian military and the IRGC.” PANHA has close ties with the IRGC; for example, in summer of 2017, it was officially reported that the company had delivered four new helicopters to the Revolutionary Guards.

Also on the list is a company that claims to be private. Pardazan System Namad Arman (PASNA), known as PASNA Electronic, has, according to the US government, “sought to procure various types of lead zirconium tritanate (PZT) items valued at hundreds of thousands of dollars from China-based Bochuang Ceramic, Inc. on behalf of Iran's ECI [Electronic Components Industries]. PZT items can transmit and receive electrical signals, and are used for anti-submarine warfare, torpedoes, mines, mine countermeasures, aircraft and ocean surveillance purposes.”

The company was registered in 2011, at the height of the sanctions regime, and almost immediately opened offices in China, Hong Kong, Malaysia and Germany, apparently to bypass the sanctions.