When Joe Biden became US president in January 2021, officials in the Islamic Republic of Iran expected that Donald Trump’s successor would not impose new sanctions on the country; in this, they were mistaken. President Biden’s administration was also expected to return to the nuclear deal known as the Joint Comprehensive Plan of Action (JCPOA) – and while it has not expanded nuclear sanctions against Iran it has imposed new sanctions related human rights violations and against the Islamic Revolutionary Guards Corps (IRGC) and its expeditionary Quds Force.
The United States has, it is true, removed some Iranian nations from the sanctions list. And the US government has made it easier for pharmaceuticals and other companies to export covid vaccines and medical products to Iran. But this does not mean the overall sanctions regime has changed. Software export to Iran remains sanctioned, for instance, though Iranian students at American universities who have remained in Iran because of covid travel restrictions and other barriers can secure temporary permission to use these tools.
The following article is a guide to the ongoing and new sanctions on the Islam Republic under the Biden administration. Similar guides were published (in Persian) about sanctions under Donald Trump and sanctions by the European Union.
October 27, 2023: Sanctions on Two Officials of the Quds Force and a Palestinian Residing in Tehran for Providing Financial Support to Hamas
On October 27, 2023, 20 days after the Hamas attack on Israel, the US Treasury targeted sources of financial support for Hamas which had already been designated as a terrorist organization. For the first time it sanctioned Iranian nationals for supporting Hamas. Those sanctioned were Ali Morshed Shirazi and Mostafa Mohammad Khani, two officials of the IRGC’s expeditionary Quds Force, for training and helping Palestinian Islamic Jihad and Lebanese Hezbollah.
Also sanctioned was Khaled Qaddoumi, a Jordanian national and longtime Hamas member who currently resides in Tehran as the group’s representative and acts as a liaison with the Iranian government. The US Treasury says Qaddoumi works to maintain strong relationships with Iran by attending delegation meetings with high-ranking Iranian officials and praising the Iranian government’s support for Hamas, including for providing the group with weapons. And the Al-Ansar Charity Association was sanctioned for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the Iranian Martyrs Foundation and Hamas.
According to the Treasury’s Office of Foreign Assets Control (OFAC), Ali Ahmad Faizullahi is an Iran-based commander of the Saberin Special Forces Brigade of the IRGC Ground Force. The Saberin Brigade has been deployed to Syria and has trained Hamas and Hezbollah. It also played a role in the violent suppression of domestic protests in Iran.
OFAC says that the Iranian Bonyad Shahid, also known as the Martyrs Foundation, which was sanctioned in 2007, provides millions of dollars through the Gaza-based and Islamic Jihad-affiliated Al-Ansar Charity Association, for the families of terrorists affiliated with Hamas and Islamic Jihad.
According to OFAC’s report, Al-Ansar claims to provide funds to families affiliated with these groups as an extension of Iranian support to the Palestinian people. But the funding is ultimately used as a recruitment tool for terrorist activities. Some of the funds have been provided through branches of Gaza-based Islamic National Bank which have been on the US sanctions list since 2010.
The report also says that Nasser Al Sheikh Ali is the director of the Islamic Jihad-affiliated Al-Ansar and has reported financial awards from the Iranian Martyrs Foundation given to families affiliated with Palestinian terrorist groups. Al Sheikh Ali has publicly acknowledged Iran’s support to Al-Ansar through the Martyrs Foundation, intended to provide financial assistance to families of Palestinian terrorist groups that have conducted terrorist attacks targeting Israel.
After issuing these sanctions, OFAC announced that its action targeted additional assets in Hamas’s investment portfolio and individuals who are facilitating sanctions-evasion by Hamas-affiliated companies.
“Today’s action underscores the United States’ commitment to dismantling Hamas’s funding networks by deploying our counterterrorism sanctions authorities and working with our global partners to deny Hamas the ability to exploit the international financial system,” Deputy Secretary of the Treasury Wally Adeyemo said, regarding the October 27 report. “We will not hesitate to take action to further degrade Hamas’s ability to commit horrific terrorist attacks by relentlessly targeting its financial activities and streams of funding.”
October 18, 2023: Sanctions on 11 Individuals, 8 Entities and a Ship
On October 18, 2023, after United Nations restrictions on Iran’s missile-related activities under UN Security Council Resolution 2231 had expired, OFAC announced that it had imposed fresh sanctions on 11 individuals, eight entities, and a container ship. The targets were based in Iran, Hong Kong, China, and Venezuela, and were believed to be enabling Iran’s destabilizing ballistic missile and unmanned aerial vehicle (UAV or drone) programs. “The persons designated today have materially supported Iran’s Islamic Revolutionary Guard Corps (IRGC), Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the production and proliferation of missiles and UAVs.” These sanctions were imposed jointly with the US Department of State and the US Treasury.
“Iran’s reckless choice to continue its proliferation of destructive UAVs and other weapons prolongs numerous conflicts in regions around the world,” said the US Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson, after these sanctions were announced. “The United States will continue to take action to disrupt Iran’s proliferation of UAVs and other weapons to oppressive regimes and destabilizing actors, and we encourage the international community to do the same.”
In addition to these sanctions, the Treasury announced that, in coordination with the US Departments of State, Commerce, and Justice, it was issuing new public guidance to private industry regarding Iranian missile procurement and related US sanctions and export restrictions.
The sanctioned entities in this category include Iran-based Fanavaran Sanat Ertebatat Company, which produces guidance systems resistant to radar jamming, for the IRGC’s Aerospace Force Self-Sufficiency Jihad Organization (IRGC ASF SSJO), an organization involved in Iranian ballistic missile research and flight test launches, and Saberin Kish Company, an Iran-based, IRGC-owned company that procures components for the IRGC to repair its intercept and technical equipment.
According to OFAC, Alireza Matinkia, an Iran-based procurement agent, facilitated the shipment of Japan- and US-origin, dual-use electronic components from Hong Kong to Iran in support of Saberin Kish’s procurement activities. (The term “dual use” refers to an item that can be used for either civilian or military purposes.) Matinkia also coordinated the purchase of US-origin electronic parts for Saberin Kish using a China-based intermediary.
Other sanctioned entities include Electro Optic Sairan Industries Company (SAPA), a subsidiary of Iran Electronics Industries that procures military equipment, Sarmad Electronic Sepahan Company that has produced two types of components identified in Mohajer-6 drones downed by Ukrainian forces, and Rayan Roshd Afzar, for having provided material support for Iran’s Shiraz Electronics Industries (SEI) and the IRGC, respectively.
According to OFAC’s report, since at least 2014, Emily Liu, a Chinese woman, has sought to procure US- and Western-origin electronic components for SEI, responsible for producing various equipment including radars, avionics and control systems, and missile guidance technology for Iran’s military. Rayan Roshd has produced technical components for the IRGC’s UAV program and worked to produce software for the IRGC’s aerospace program.
China-based Yongxin Li, also known as Emma Lee, is an associate of Emily Liu who supported the procurement of various dual-use electronics including printed circuit boards, ultrasonic sensors, diodes, oxygen sensors, and integrated circuits on multiple occasions for Rayan Roshd. Hong Kong-based Yiu Wa Yung, also known as Stephen Yung, worked with Emma Lee to facilitate procurement and arrange shipments for Rayan Roshd.
Two sanctioned individuals, Iran-based Armin Ghorsi Anbaran and Hossein Hemsi, are the directors and shareholders of Fanavaran Sanat Ertebatat Company (FSE), each with a 50 percent stake in the company.
Some individuals listed in this report have already been sanctioned but here OFAC associates them with other activities that strengthens the cases against them. They include Iranian Defense Minister Mohammad-Reza Ashtiani, Seyed Hojatollah Ghoreishi, Deputy Minister of Defense and Armed Forces Logistics (MODAFL), Jaber Reihani, Iran’s Defense Attaché in Venezuela and Seyed Hamzeh Ghalandari, MODAFL’s Director-General for International Relations.
The cargo vessel Parnia has also been sanctioned. The OFAC report states that Parnia has been used by MODAFL for defense exports to other countries and it recently transported several Iranian Peykaap III fast attack missile patrol boats to Venezuela.
Several companies in China, Hong Kong and Venezuela which are active in electronics and technology used in ballistic missiles and drones, have also been put on the sanctions list, along with their financial intermediaries.
The OFAC report declares that “As a result of today’s action, all property and interests in property of the individuals and entities named above, 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 US persons must be blocked and reported to OFAC. All transactions by US persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons are prohibited.”
The report also warns that “persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today … could be subject to US sanctions.”
September 27, 2023: Sanctions on 7 Individuals and Entities that Facilitate Purchases of Drone Parts
On September 27, 2023, the US Department of Treasury sanctioned two individuals and five companies based in the United Arab Emirates (UAE), Turkey, Hong Kong and the Islamic Republic of Iran for helping the IRGC to procure sensitive parts for the production of drones.
The sanctioned individuals were Ms. Yang Fan (a.k.a. "Cathy"), CEO of Hongkong Himark Electron Model Ltd, and Hamid Reza Janghorbani, CEO of Pishgam Electronic Safeh Company, based in Isfahan.
Entities sanctioned are Hong Kong Himark Electron Model Limited in China, Pishgam Electronic Safeh in Iran, Anka Port Lojistik Sanayi Ltd and Dal Enerji AS in Turkey, and Farhad Ghaedi Wholesalers LLC in the UAE.
In a press release, OFAC announced that the individuals and companies listed above had been “involved in the procurement of sensitive parts for Iran’s one-way attack unmanned aerial vehicle (UAV) program. This network has facilitated shipments and financial transactions in support of the IRGC ASF SSJO’s procurement of servomotors, a critical component used in Iran’s Shahed-series UAVs. Iran has been supplying Russia with Shahed-136 UAVs to support Russia’s illegal invasion of Ukraine. One of the servomotors procured by the network designated today was recovered in the remnants of a Russia-operated Shahed-136 that was recently shot down in Ukraine.”
“Iranian-made UAVs continue to be a key tool for Russia in its attacks in Ukraine, including those that terrorize Ukrainian citizens and attack its critical infrastructure,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson.
September 25, 2023: Sanctions on Russian-Iranian Joint Stock Turbine Maker
On September 25, 2023, OFAC sanctioned a Russian-Iranian joint stock company because of its contribution to proscribed Russian military programs.
Joint Stock Company Star has been charged with working with Iran Aircraft Manufacturing Industrial Company (HESA) in the production of drones.
September 19, 2023: Sanctions on 7 Individuals and 4 Companies in China, Iran, Russia and Turkey for Supporting Military Aircraft Production in Iran
On September 19, 2023, OFAC sanctioned four companies and seven individuals, nationals of Iran, China, Russia and Turkey, for supporting Iran’s UAV and military aircraft production by Iran Aircraft Manufacturing Industrial Company (HESA).
The sanctioned individuals were:
— Hossein Omid (aka Ayini), Iranian, HESA’s director of UAV manufacturing
— Turkey-based money exchangers Mehmet Tokdemir and Alaaddin Aykut for facilitating US dollar- and euro-denominated financial transactions worth hundreds of thousands of dollars in support of HESA’s procurement from various suppliers
— China-based Dong Wenbo who represented the Chinese Guilin Alpha Rubber and Plastics Technology Company in the sale of aircraft brake disks to HESA
— Iran-based Mehdi Gogerdchian, HESA’s managing director and a member of the firm’s board of directors
— Iran-based Hamidreza Noori, HESA’s vice chairperson of the board of directors
— China-based Su Chunpeng, managing director and owner of Shenzhen Jiasibo, for providing a wide range of support for HESA.
Sanctioned companies included Russia-based Delta-Aero Technical Service Center LLC for suppling propellers and tires to HESA for its AN-140 aircraft, the Russia-based Joint Stock Company Scientific Production Enterprise Aerosila for performing ground and flight tests for HESA and for facilitating the supply of auxiliary power units to this company, and Russia-based Joint Stock Company Star that has contracts with HESA to overhaul components of the AN-140 aircraft.
In its press release, US Treasury announced: “HESA manufactures Iran’s Ardabil- and Shahed-series UAVs. It was designated pursuant to E.O. 13382 on September 17, 2008, for being owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and for having provided support to Iran’s Islamic Revolutionary Guard Corps (IRGC). As of 2022, HESA has used the name Shahin Co. in contracts with overseas-based suppliers in an apparent effort to evade US sanctions and export controls. Because HESA continues to procure sensitive UAV components under this name, OFAC is updating HESA’s entry on the SDN List to include Shahin Co. as an alias.”
At the same time, OFAC removed four Liberian-flagged tankers from the sanctions list related to the Islamic Republic of Iran.
September 18, 2023: Sanctions on Former President Mahmoud Ahmadinejad and the Islamic Republic’s Intelligence Ministry
On September 18, 2023, while a prisoner exchange between Iran and the United States was in progress, OFAC imposed sanctions on former president Mahmoud Ahmadinejad, who is now a member of the Expediency Council, and on the Ministry of Intelligence of the Islamic Republic.
“Today’s action targets Mahmoud Ahmadinejad for enabling the wrongful detention of our citizens, causing immeasurable pain and suffering for both the victims and their families,” said US Under Secretary Brian E. Nelson. “We remain strongly committed to the victims and their families, and are resolute in our efforts to hold accountable those who perpetrate these acts.”
These sanctions were based on the authority of the 2020 Robert Levinson Hostage Recovery and Hostage Taking Accountability Act, named after Robert Levinson, a retired FBI agent who had traveled to the Iranian island of Kish in March 2007 but then disappeared and is now feared to be dead.
The Levinson Act, signed into law in 2020, is aimed at holding accountable governments that take Americans hostage. The law covers not only American citizens but also holders of US residency permits.
As a result of these sanctions, any asset or property that might belong to the Ministry of Intelligence or Ahmadinejad, and lies within the jurisdiction of the United States, is to be blocked. The former president and members of his family are also not allowed to enter the US.
September 15, 2023: Sanctions on 29 Individuals and Entity on the Anniversary of Mahsa Amini’s Death
On September 15, 2023, OFAC announced that it was sanctioning 29 individuals and entities in connection with “the Iranian regime’s violent suppression of nationwide protests following the death of Mahsa ‘Zhina’ Amini in custody of its ‘Morality Police,’ and the regime’s continued efforts to detain dissenting voices and restrict access to a free and open internet.”
According to OFAC’s announcement, the following individuals were sanctioned:
— Brigadier General Saeed Montazerolmehdi, Social Deputy and Spokesperson of the National Police, officially called the Law Enforcement Forces (LEF). Montazerolmehdi had participated in the planning and announcement of strict LEF policies against Iranian women who disobey compulsory hijab rules.
— Brigadier General Hossein Amjadian, commander of the Police Special Unit in Tehran who previously commanded the Police Special Unit in Isfahan Province from 2016 to 2019. He was involved in the killing hundreds of protesters.
— Brigadier General Abbasali Mohammadian, Police Commander of Tehran Province.
— Brigadier General Hassan Shahrestani, Police Commander of Mazandaran Province who was previously the head of Iran’s Morality Police. Shahrestani reportedly instructed his subordinates to “break the neck of anyone” violating Iran’s hijab rules, and reportedly warned that businesses whose employees removed their headscarves in the workplace face closure.
— Brigadier General Ahmad Taheri, Police Commander in Sistan and Baluchistan province from October 2020 to November 2022. During his tenure, police forces were involved in the September 30, 2022, massacre of protesters and civilians in Zahedan, the capital of Sistan and Baluchistan province, now known as “Bloody Friday”.
— Ahmad Naderian, Deputy Police Commander of Sistan and Baluchistan who was the Deputy Police Commander during Bloody Friday.
— Seyyed Khalil Safavi, Police Commander in Rezvan Shahr city in Gilan province since February 2022. During his previous tenure as the Police Commander of the city of Rasht in Gilan Province, forces under his command reportedly killed at least three individuals and injured several others during a September 21, 2022, demonstration.
— Delavar Alghasi-Mehr, Police Commander of eastern Tehran Province. He was previously the Police Commander of Shiraz from 2016 to 2019 and was then the Police Commander of Ilam Province.
— Mohammad Moazami Goudarzi, the Commander of the Prevention Police of Tehran, a specialized branch of the National Police. During his previous tenure as Deputy Commander of Police Karaj, Goudarzi was responsible for the suppression of the November 2019 protests in that city. Goudarzi commanded forces who used lethal force resulting in the deaths of at least 10 protesters.
— Roham Bakhsh Habibi, Police Commander of Fars province. Forces under Habibi’s control reportedly participated in the violent suppression of protests in November 2019.
— Khodarahm Sarani, the IRGC Commander in Zahedan. In February 2021, IRGC forces under Sarani’s command reportedly used lethal force against unarmed protesters in Zahedan, resulting in the deaths and injuries of a number of protesters, including a 13-year-old child. The IRGC also opened fire on Baluch fuel porters protesting the IRGC-directed closing of a border crossing, killing at least 10 carriers.
— Mazaher Majidi, the IRGC Commander in Hamedan Province who oversees units involved in suppressing protests. Security forces in the province have used lethal force against protestors. Majidi publicly announced that, in October 2022 alone, over 700 protestors were arrested in Hamedan province.
— Bahman Reyhani, the IRGC Commander of Kermanshah Province and the Nabi Akram Corp. Reyhani commanded units reportedly tasked with suppressing dissent and demonstrations, which they did during the nationwide November 2019 protests.
— Jamal Shakarami, an IRGC Commander in Ilam Province, an area where the IRGC has played a central role in suppressing dissidents and protests.
— Mohammad Abdollahpour, the Commander of Gilan Quds Brigade, a provincial branch of the IRGC. Abdollahpour participated in the enforcement of harsh security policies against women who disobeyed Iran’s mandatory hijab rules. He also reportedly supervised the IRGC’s suppression of protests following the death of Mahsa Amini.
— Brigadier General Gholamhossein Gheib-Parvar, the Deputy Commander of the IRGC in the Central Security headquarters of Imam Ali security base.
— Ali Akbar Pour-Jamshidian, the Commander of Hamzeh Seyyed al-Shohada Base of the IRGC Ground Forces. He was previously the deputy coordinator of the IRGC Ground Forces.
— Abdolreza Abedzadeh, the newly appointed Commander of Khatam al-Anbiya Construction Headquarters, an IRGC-controlled construction conglomerate that undertakes multi-billion-dollar projects in the oil, petrochemical, and various infrastructure sectors, generating revenue for the IRGC and expanding its control across multiple industries.
— Gholamali Mohammadi, head of Iran’s Prisons Organization. Under his leadership, serious human rights abuses have occurred throughout Iranian prisons, including the use of torture or other cruel, inhumane or degrading treatment or punishment, detention and physical abuse of political dissidents and religious minorities, sexual violence and coercion against female prisoners, including rape, and the abuse and torture of children.
— Alireza Abedinejad, the CEO of Doran Software Technologies, a leading company in Iran assisting the government in censorship and filtering of the Internet.
Sanctions on Press TV, Tasnim News Agency and Fars News Agency
Also sanctioned on the anniversary of Mahsa Amini’s death and the start of nationwide protests were the following media outlets:
— Press TV, the English-language channel for the state broadcaster of the Iranian government, Islamic Republic of Iran Broadcasting (IRIB), which was designated by the United States in 2013 for participating in censorship. Press TV has broadcast scores of forced confessions and derogatory programs about Iranian activists, in many cases broadcasting forced confessions before detainee trials. Press TV has also been used by Iranian intelligence services to recruit sensitive assets, including US persons.
— Tasnim News Agency, a news outlet founded by two IRGC commanders, Majid Gholizadeh and Hamidreza Moghadam Far, who continue to serve as Tasnim executives and control Tasnim on behalf of the IRGC. Tasnim has supported the IRGC and other instruments of the regime in various ways, including suppressing dissent by helping the IRGC, Iran’s Ministry of Intelligence, and the National Police to crowdsource the identities of protestors.
— Fars News Agency is closely affiliated with the IRGC and has provided special intelligence reports to Hossein Salami, commander-in-chief of the IRGC.
As a result of this set of sanctions, all property and interests in property of the individuals and entities that are in the United States or in the possession or control of US persons must be blocked and reported to OFAC.
June 2, 2023: Sanctions on 2 Individual Related to Arvan Cloud and An Affiliated Company in Dubai
On June 2, 2023, OFAC added the Iran-based technology company Arvan Cloud, two of its senior employees and an affiliated company based in the United Arab Emirates to its list of human rights violators for their roles in facilitating the Iranian regime’s online censorship in Iran.
The two sanctioned individuals are Pouya Pirhosseinloo and Farhad Fatemi, co-founders of Arvan Cloud who serve as the CEO and the tech lead and senior site reliability engineer, respectively.
Also sanctioned was Arvan Cloud Global Technologies LLC, a Dubai-based affiliate of Arvan Cloud that provides cloud services on behalf of Arvan Cloud and provides a bridge for Arvan Cloud’s connection to the global internet.
According to OFAC, with the help of Arvan Cloud, “The Iranian government has regularly used Internet restrictions and the throttling of Internet speeds to suppress dissent, surveil and punish Iranians for exercising their freedom of expression and assembly both online and offline, and limit the dissemination to the international community of credible information about egregious human rights violations.”
June 1, 2023: Sanctions on Rey Airlines, Members of IRGC Intelligence Organization in Connection with Assassinations Outside Iran
On June 1, 2023, OFAC imposed sanctions on senior officials of the IRGC Intelligence Organization (IRGC-IO), its expeditionary Quds Force and their operatives outside Iran. These sanctions apply to five Iranian nationals based in Iran and Turkey, including high-level officials of IRGC-IO, and to a company affiliated with the Quds Force.
The sanctioned Iranian nationals are:
— Reza Seraj, the IRGC-IO Foreign Intelligence Chief, who has been involved in failed IRGC-IO operations in Asia and in intelligence operations targeting US citizens. Seraj previously led the IRGC-IO Special Operations Division, which is focused on special activities against Israel, where he was responsible for a series of failed operations targeting Israeli nationals.
— Ruhollah Bazghandi, former IRGC-IO Counterespionage Department Chief. He has been involved in planning and overseeing IRGC-IO operations in Iraq and Syria as well as lethal operations against Israeli nationals. Bazghandi has also been involved in plots to assassinate journalists and Israeli nationals in Istanbul.
— Mohammad Reza Ansari, a longtime member of the Quds Force, who has supported Quds Force operations in Syria. Ansari is a member of the Quds Force external operations unit tasked with undertaking covert operations abroad, including planning and conducting intelligence and lethal operations against Iranian dissidents and other non-Iranian nationals in the United States, the Middle East, Europe, and Africa.
— Shahram Poursafi, also known as Mehdi Rezaei, a member of the IRGC who planned and attempted to assassinate two former US government officials. Poursafi has also been involved in Quds Force operational planning and surveillance operations in the Caucasus region. In August 2022, Poursafi was indicted by the US Justice Department for plotting to assassinate John Bolton, National Security Advisor to former US president Donald Trump as well as a US ambassador to the United Nations, and attempting to pay $300,000 to individuals in the US to carry out the assassination.
— Hossein Hafez Amini, a dual Iranian and Turkish national based in Turkey and part of the Quds Force network in Turkey. Amini uses his connections in the aviation industry and his Turkey-based airline, Rey Airlines, to assist Quds Force covert operations, including kidnapping and assassination plots targeting Iranian dissidents in Turkey.
Rey Airlines itself was also sanctioned for being owned, controlled, or directed by, directly or indirectly, by Hossein Hafez Amini.
As a result of these sanctions, all property and interests in property of sanctioned 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 US persons, are blocked. Also, all transactions with these individuals and entities has been prohibited.
“The United States remains focused on disrupting plots by the IRGC and its Qods [sic] Force, both of which have engaged in numerous assassination attempts and other acts of violence and intimidation against those they deem enemies of the Iranian regime,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “We will continue to expose and disrupt these terrorist activities and efforts to silence opposing voices, particularly those who advocate for respect for the universal human rights and freedoms of the Iranian people.”
April 27, 2023: Sanctions on Russian and Islamic Republic Officials for Wrongfully Arresting American Nationals
On April 27, 2023, OFAC for the first time sanctioned a number of Russian and Iranian nationals for wrongfully arresting American nationals and taking them hostage. In this round of sanctions, the Revolutionary Guards’ Intelligence Organization (IRGC-IO), four of its senior commanders and also the Russian Federal Security Service (FSB) were targeted.
Iranian nationals who were sanctioned are:
— Ruhollah Bazghandi, the IRGC-IO Counterintelligence official. In this role, Bazghandi was involved with the detention of foreign prisoners held in Iran. Bazghandi has worked on behalf of the IRGC-IO in several capacities, including involvement in IRGC-IO’s operations in Syria, and assassination plots against journalists, Israeli citizens, and others deemed enemies of the Islamic Republic.
— Mohammad Kazemi, commander of the IRGC-IO. According to OFAC, Kazemi oversees the IRGC-IO’s operations suppressing civil society in Iran and arresting Iranian dissidents, including dual nationals. He has also overseen the regime’s brutal crackdown against protests across the country in response to the killing of Mahsa Amini.
— Mohamad Mehdi Sayyari, the IRGC-IO Co-Deputy Chief. Sayyari has been directly involved in arranging logistics for prisoners in Iran.
— Mohammad Hasan Mohagheghi, the IRGC-IO Co-Deputy Chief Brigadier General. He reports to several senior IRGC Commanders on RGC-IO operations. Mohagheghi served as a liaison between senior IRGC officials and IRGC-IO officials on counterespionage operations in Syria.
April 24, 2023: Sanctions on 5 Military Violators of Human Rights and the Secretary of the Supreme Council of Cyberspace
On April 24, 2023, the US Treasury added the names of four IRGC commanders and an Islamic Republic official to its list of violators of human rights and imposed sanctions on them. They are:
— Brigadier General Parviz Absalan, the Deputy Commander of the IRGC Salman Corp of Sistan and Baluchistan. The Salman Corp were involved in the violent suppression of protests in Sistan and Baluchistan, which resulted in some of the highest casualties nationwide following the outbreak of protests in September 2022.
— Brigadier General Amanollah Goshtasbi, Deputy Inspector of the IRGC’s Ground Forces. He was previously the Commander of the IRGC’s Salman Corp, during which forces under his command are alleged to have opened fire on Baluch citizens on multiple occasions, leading to several deaths.
— Brigadier General Ahmed Khadem Seyedoshohada, Commander of the IRGC’s Karbala operational base. During the 2022 protests, IRGC troops under his command allegedly used live ammunition against protesters in the towns of Khorramabad, Lorestan province, and Izeh, Khuzestan province.
— Brigadier General Salman Adinehvand, Commander of the Tehran Police Relief Unit of Iran’s National Police, the primary security organization in charge of crowd control and protest suppression. Adinehvand’s unit was directly responsible for the violent suppression of protests in Tehran in September and October 2022, during which dozens of protestors were killed by security forces using live ammunition.
— Mohammad Amin Aghamiri, Secretary of Supreme Council of Cyberspace (SCC), the centralized authority regarding policymaking in the realm of cyberspace. The SCC is responsible for Iran’s blockage of popular online news and communications platforms and has also used digital technology to spy on and harass journalists and regime dissidents.
These individuals and members of their immediate families are banned from entering the United States and all their property and interests in the US, if any, will be blocked.
“The Iranian people deserve freedom of expression without the threat of violent retaliation and censorship from those in power,” said Brian E. Nelson. “Along with our key allies and partners, such as the United Kingdom, the United States will continue to take action against those responsible for the regime’s violent repression and censorship.”
April 19, 2023: Sanctions on 4 Individuals and 6 Companies in a Network for Providing Electronic Components for Iran’s Drone Program
On April 19, 2023, OFAC imposed sanctions on four individuals and six entities involved in a sanctions evasion network that has facilitated Iran’s procurement of electronic components for its destabilizing military programs, including those used to manufacture drones.
The four individuals are Iranian national Mehdi Khosh-Ghadam, managing director of Iran’s Pardazan System Namad Arman (PASNA), based in Malaysia, and three Nicaraguan nationals, Ernesto Leonel Rodriguez Mejia, Octavio Ernesto Rothschuh Andino and Nadia Camila Tardencilla Rodriguez.
The six companies that, according to OFAC, provide components for Iran’s weapons program are Iran-based Amvaj Nilgoun Bushehr, Malaysia-based PASNA International, Hong Kong-based Arttronix International (HK) Limited, Jotrin Electronics Limited, China-based Vohom Technology (HK) Company Limited and Hong Kong-based Yinke (HK) Electronics Company Limited.
According to this announcement, Mehdi Khosh-Ghadam is responsible for the company’s sanctions evasion efforts. Using numerous front companies, Khosh-Ghadam has sought a variety of electronic components from foreign suppliers primarily based in China.
“The network sanctioned today has procured goods and technology for the Iranian government and its defense industry and UAV program,” said Brian E. Nelson. “[The US] Treasury will continue to enforce its sanctions against Iran’s military procurement efforts that contribute to regional insecurity and global instability.”
March 21, 2023: Sanctions on 3 Iranian and Turkish Nationals and 4 Iranian Entities
On March 21, 2023, the first day of the Iranian calendar year, the US Treasury Department put sanctions on seven individuals and entities for procuring components and supporting Iran’s UAV and weapons programs. This procurement network operates on behalf of Iran’s Ministry of Defense and Armed Forces Logistics which oversees several firms involved in UAV and ballistic missile development.
The sanctioned individuals are:
— Iran-based Asghar Mahmoudi who has procured items with UAV applications, including inertial measurement units and attitude and heading reference systems.
— Iran-based Amanollah Paidar, who worked with Mahmoudi as a commercial manager and procurement agent.
— Murat Bukey, a Turkish national who used his now-dormant company Ozone Aviation, based in Izmir, to facilitate the procurement of goods with defense applications including chemical and biological detection devices, for Paidar. Bukey also attempted to provide European-origin engines with UAV and surface-to-air missile applications to Paidar and, separately, sold more than 100 European-origin UAV engines and related accessories worth more than $1 million to companies that likely transshipped the items to Iran.
Sanctioned entities are Iran-based Defense Technology and Science Research Center, Farazan Industrial Engineering, Inc., Ozone Aviation and Defense Industry Inc. and Selin Technic Company, for helping the Islamic Republic’s drone program.
“Iran’s well-documented proliferation of UAVs and conventional weapons to its proxies continues to undermine both regional security and global stability,” said Brian E. Nelson. “The United States will continue to expose foreign procurement networks in any jurisdiction that supports Iran’s military industrial complex.”
March 9, 2023: Sanctions on 44 Companies in Hong Kong, Pakistan, Singapore, UAE, China, Marshall Islands, Turkey and Iran, and on a Chinese National
On March 9, 2023, the US Treasury sanctioned 44 companies in Hong Kong, Pakistan, Singapore, UAE, China, Marshall Islands, Turkey and Iran for violating bans related to the Islamic Republic’s drone program and to Iran’s petrochemical products.
OFAC sanctioned 39 entities, constituting a significant “shadow banking” network, one of several multi-jurisdictional illicit finance systems which grant sanctioned Iranian petrochemical entities access to the international financial system and obfuscate their trade with foreign customers. This network generates the equivalent of tens of billions of dollars annually for the Iranian regime.
Five companies in China and Hong King are accused of helping the Islamic Republic’s drone program. Also sanctioned was Yun Xia Yuan for violating sanctions imposed on Iran. According to OFAC, these entities have helped Iran to develop and producing Shahed-136 UAV model that Iran has used to attack oil tankers and has exported to Russia.
March 8, 2023: Sanctions on 8 Individuals and 3 Entities for Violating the Human Rights of Iranian Women
On International Women's Day, March 8, 2023, OFAC added eight Islamic Republic officials and three entities affiliated with the Iranian regime to its list of human rights violators for serious human rights abuses against women and girls.
The sanctioned individuals are:
— Major General Abdolrahim Mousavi, Commander-in-Chief of the Islamic Republic of Iran Army.
— Ali Chaharmahali, Director-General of Alborz Province Prisons, a region that is home to some of Iran’s most notorious prisons.
— Dariush Bakhshi, the head of Urmia Central Prison in West Azerbaijan province.
— Reza Asgharian, the CEO of Naji Pas Company which is responsible for supplying Iran’s security services.
— Bahram Abdollahinejad, CEO of Naji Pars Amin Institute which is licensed by the Iranian National Police to provide a wide range of protection and security services for various Iranian businesses and government facilities.
— Gholamreza Ramezanian Sani, CEO of Entebagh Gostar Sepehr Company which manufactures or imports a wide variety of police-related equipment.
— Mahdi Amiri, Technical Director to the Cyberspace Affairs Deputy of the Prosecutor General’s Office for his role in restricting access to the internet.
— Habib Shahsavari, IRGC Commander of the Shohada Provincial Corps in West Azerbaijan province.
The companies sanctioned were Naji Pas, Naji Pars Amin and Entebagh Gostar Sepehr Company for providing Islamic Republic security forces with the means to violently suppress protesters, especially women and girls.
“The United States, along with our partners and allies, stand with the women of Iran, who advocate for fundamental freedoms in the face of a brutal regime that treats women as second-class citizens and attempts to suppress their voices by any means,” said Brian E. Nelson. “We will continue to take action against the regime, which perpetuates abuse and violence against its own citizens—especially women and girls.”
OFAC’s press release points out that “Iran’s prisons are notorious for mistreatment, abuse, and death. Women prisoners, especially, suffer sexual violence, torture, and other cruel, inhumane, and degrading treatment.”
March 2, 2023: Sanctions on Petrochemical Companies in Mexico, China, Iran, UAE and Vietnam and on 20 Oil Tankers
On March 2, 2023, the US Treasury sanctioned additional shipping companies in Mexico, China, Iran, United Arab Emirates (UAE) and Vietnam in connection with Iran’s oil, gas and petrochemicals industry. Also sanctioned were 20 ships and oil tankers.
Sanctioned companies include Iran-based Shiraz Petrochemical and Bushehr Petrochemical, UAE-based Swedish Management, Mexico-based Corporativo Title I, Corporativo TS Business Inc, TS Business Corporativo, Servicios Administrativos Fordtwoo, Integracion Badeva, JM Providers Office, Promotora Vallarta One, Recservi, China-based Global Marine Ship Management, Shanghai Xuanrun Shipping Company Limited and Vietnam-based Golden Lotus Oil Gas and Real Estate Joint Stock Company.
The following cargo ships and oil tankers were also added to the sanctions list: Amias Chemical/Products Tanker (Vietnam flag), Cattle Force Livestock Carrier (Togo flag), Dolphin LPG Tanker (Sao Tome and Principe flag), Forever Rich Chemical/Products Tanker (Hong Kong flag), Full Star Chemical/Products Tanker (Hong Kong flag), Gas Cathar LPG Tanker (Panama flag), Gladiator Tug (Togo flag), Golden Bridge Bulk Carrier (Panama flag), Golden Light 09 Bulk Carrier (Vietnam flag), Golden Phoenix Bulk Carrier (Panama flag), Hercules Offshore Tug/Supply Ship (Togo flag), Jamaica Crude Oil Tanker (Vietnam flag), Lauren LPG Tanker (Tuvalu flag), Liang Sheng Chemical/Products Tanker (Hong Kong flag), Rising Eagle Bulk Carrier (St. Vincent and the Grenadines flag), Rising Falcon Bulk Carrier (St. Vincent and the Grenadines flag), Rising Harrier Bulk Carrier (St. Vincent and the Grenadines flag), Xuan Ning Chemical/Products Tanker (China flag), Yong Xiang 29 Chemical/Products Tanker (China flag), Yong Xin Chemical/Products Tanker (Hong Kong flag).
February 9, 2023: Sanctions on Petrochemical Companies in Singapore, Malaysia and Iran
On February 9, 2023, OFAC added a number of companies in Singapore, Malaysia and Iran to its sanctions list in connection with the Iranian petrochemical industry.
In this round, the US Treasury targeted six Iran-based petrochemical manufacturers or their subsidiaries, and three firms in Malaysia and Singapore involved in facilitating the sale and shipment of petroleum and petrochemical products for the Islamic Republic of Iran.
These companies are Amir Kabir Petrochemical Company (AKPC), a major polyethylene producer in Iran, Simorgh Petrochemical Company, a fully-owned subsidiary of AKPC, Iran-based Laleh Petrochemical, Marun Tadbir Tina Company, Marun Sepehr Ofogh Company, and Marun Supplemental Industries, Singapore-based Asia Fuel PTE Limited that has facilitated the shipment of petroleum products worth millions of dollars to customers in East Asia, Sense Shipping and Trading in Malaysia and Singapore-based Unicious Energy PTE Limited.
“Iran is increasingly turning to buyers in East Asia to sell its petrochemical and petroleum products, in violation of US sanctions,” said Brian E. Nelson. “The United States remains focused on targeting Tehran’s sources of illicit revenue, and will continue to enforce its sanctions against those who wittingly facilitate this trade.”
February 3, 2023: Sanctions of 8 Individuals and 2 Navy Ships in Connection with Drones Production
On February 3, 2023, OFAC updated its list of sanctions against the Islamic Republic in the context of “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters" and the fight against terrorism by adding two Iranian navy ships and eight individuals.
In this update , sanctions were imposed on individuals connected with Paravar Pars Company, an Iran-based firm that was previously sanctioned by the United States and European Union for manufacturing Shahed-series drones for the IRGC: Hossein Shamsabadi, Paravar Pars’ Managing Director and CEO, General Ali Reza Tangsiri, Chairman of the Board for Paravar Pars and also the Commander of the IRGC Navy, Abolfazl Nazeri, Vice Chairman of the Board of Directors for Paravar Pars, Mohsen Asadi, a member of Paravar Pars’ Board of Directors, Mohammad Sadegh Heidari Mousa, a member of Paravar Pars’ Board of Directors and also an IRGC Navy official, Mohammad Reza Mohammadi and Abolghasem Valagohar, both members of Paravar Pars’ Board of Directors.
Also sanctioned were two IRGC ships, IRIS Makran, an oil tanker that was repurposed for naval operations and which maintains UAV launch capabilities, and the naval frigate IRIS Dena.
“Iranian entities continue to produce UAVs for Iran’s IRGC and military. More broadly, Iran is supplying UAVs for Russia’s combat operations to target critical infrastructure in Ukraine,” said Brian E. Nelson. “The United States will continue to aggressively target all elements of Iran’s UAV program.”
January 31, 2023: Sanctions on 7 Islamic Republic Entities for Providing Russia with Military Assistance
On January 31, 2023, the US Commerce Department put new trade restrictions on seven Iranian entities for producing drones that Russia has used in its invasion of Ukraine.
Seven Islamic Republic entities were put on the Commerce Department’s sanctions list: Design and Manufacturing of Aircraft Engines, Islamic Revolutionary Guard Corps Aerospace Force, Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jihad Organization, Oj-e Parvaz Ma do Nafar Company, Paravar Pars Company, Qods Aviation Industry, and Shahed Aviation Industries.
“The actions we’re taking today, on top of the prior actions by our interagency partners, are intended to smother these entities’ access to items that enable Russia’s illegal war of aggression against Ukraine and demonstrate our resolve to aggressively use export controls to confront Russia’s desperate attempts to source drones from the Iranian regime,” said US Under Secretary of Commerce for Industry and Security Alan Estevez.
January 23, 2023: Sanctions on the Executives of IRGC Financial Institutions, Military Commanders and Deputy Intelligence Minister
On January 23, 2023, the US Treasury sanctioned a number of IRGC military commanders and executives of its affiliated financial institutions. Also sanctioned was a deputy intelligence minister.
Sanctioned individuals included Ali Asghar Norouzi, chairman of the IRGC Cooperative Foundation’s board of directors who has played a crucial role in facilitating the transfer of funds and weapons to regional proxies in the Middle East, Aminollah Emami Tabatabai, vice chairman of the IRGC Cooperative Foundation’s board of directors and its managing director, and Ahmad Karimi, Yahya Alaeddini and Jamal Baba-Moradi, three members the IRGC Cooperative Foundation’s board of directors.
Sanctioned military commanders were Mohammad Nazar Azimi, commander of the IRGC’s Najaf Ashraf West Headquarters, responsible for the western Iranian provinces of Kermanshah, Hamadan, and Ilam, and Azimi’s deputy, Kourosh Asiabani, commander of the Shahid Kazemi Headquarters who oversees IRGC activities in Kermanshah province.
Also sanctioned was Mojtaba Fada, the IRGC commander of Isfahan Province and a member of its provincial security council who oversaw the crackdown on regime opponents in Isfahan. During nationwide protests in November 2019 sparked by economic grievances, Fada ordered mass arrests and directed the use of live ammunition against unarmed protestors, during which over 20 people were killed.
Another sanctioned commander was Hossein Tanavar, who serves as the commander of the 17th IRGC Division in Qom.
Naser Rashedi, Deputy Minister for Intelligence in the Ministry of Intelligence, was added to list of violators of human rights in Iran. In September 2022, the US Treasury had designated Rashedi’s superior, Esmail Khatib, and the Intelligence Ministry for their involvement in malicious cyber activity against the Albanian government and its people.
The IRGC Cooperative Foundation, already sanctioned by the US Treasury, is an economic conglomerate established by senior IRGC officials to manage the group’s investments and presence in numerous sectors of the Iranian economy, including manufacturing and construction. “The IRGC Cooperative Foundation serves as a slush fund for the IRGC’s personnel and their business interests,” announced OFAC. “Though ostensibly established to support IRGC service members, the IRGC Cooperative Foundation has morphed into a wellspring of corruption and graft, perpetrated by senior members of the organization. IRGC Cooperative Foundation funds have likewise supported the IRGC’s military adventures abroad, including into the pockets of militant groups associated with the IRGC’s external operations arm, the IRGC-Qods Force.”
Based on the decision of the US Department of Treasury, from this date on, the IRGC Cooperative Foundation and its senior officials will be designated as violators of human rights in Iran.
January 6, 2023: Sanctions on Suppliers of Iranian Drones Used by Russia to Target Ukraine’s Civilian Infrastructure
On January 6, 2023, OFAC sanctioned seven Iranian nationals and one entity involved in making drones used by Russia in its war of aggression against Ukraine. These sanctions were imposed pursuant to Executive [Presidential] Order 13382, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.”
Sanctioned individuals were Nader Khoon Siavash, Director of Quds Aviation Industries (QAI), a key Iranian defense manufacturer responsible for the design and production drones, Hamidreza Sharifi-Tehrani, a primary member of the Board of Directors of QAI, Majid Reza Niyazi-Angili, Vali Arlanizadeh and Reza Khaki, three members of the Board of Directors for QAI, and Hojatollah Ghoreishi, Chairman of the Board of Directors of QAI who, as Deputy Minister of Defense, has led Iran’s military research and development efforts and was responsible for negotiating Iran’s agreement with Russia for the supply of Iranian drones for Russia’s war in Ukraine.
The sanctioned entity was Quds Aviation Industries itself.
December 20, 2022: Sanctions on 4 Security and Judiciary Officials and a Manufacturer of Anti-Riot Equipment
On December 20, 2022, OFAC targeted Iran’s Prosecutor General and key military and paramilitary officials in Iran, as well as a company manufacturing and providing security forces with anti-riot equipment and added them to its list of human rights violators.
“As nationwide protests continue throughout Iran, the response from Iranian security forces has continued to escalate,” announced OFAC. “In the past two weeks, two protestors have been executed, one publicly, and several others have been sentenced to death. Today’s action targets the senior official overseeing the prosecution of protestors, as well as leaders of military and paramilitary organizations violently cracking down and detaining protestors and a company that procures and provides security forces with tools of suppression.”
Sanctioned individuals were Mohammad Jafar Montazeri, Iran’s Prosecutor General who oversees prosecutions and the enforcement of criminal judgments throughout Iran, including such actions brought in Iran’s Revolutionary Courts, the primary venue for charging those arrested in the protests, Hassan Hassanzadeh, the commander of IRGC forces in Tehran, Seyed Sadegh Hosseini, commander of the Beit-al Moghaddas Corps and IRGC Commander in Kurdistan, Hossein Maroufi, Deputy Coordinator of the IRGC-affiliate, the paramilitary Basij forces, Moslem Moein, chief of the Basij Cyberspace Headquarters which oversees efforts to control and censor Iranians’ online activities.
“We denounce the Iranian regime’s intensifying use of violence against its own people who are advocating for their human rights,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States and our partners are dedicated to holding Iranian officials to account for egregious abuses committed against Iranian citizens fighting for their fundamental freedoms.”
The sanctioned company is Imen Sanat Zaman Fara, a manufacturer of numerous types of equipment for Iran’s security forces, in particular the Police Special Units, one of the Islamic Republic’s main protest suppression forces. Among other equipment, Imen Sanat Zaman Fara produces armored vehicles, also described as “tactical” vehicles, for use in crowd suppression.
December 9, 2022: Sanctions on 3 Iranian Officials after the Execution of a Young Protester
On December 9, 2022, one day after 23-year-old protester Mohsen Shekari was hanged in Iran, the US Treasury added three Islamic Republic officials to its list of violators of human rights.
The sanctioned officials were General Ali Akbar Javidan, commander of the police in Kermanshah Province who has direct oversight over forces that have killed protesters, including children and the elderly, Colonel Ebrahim Kouchakzaei, police commander of Chabahar in Sistan and Baluchistan Province who was accused of raping a 15-year-old girl, and Allah Karam Azizi, the warden of Iran’s notorious Rajaee Shahr Prison.
December 8, 2022: Sanctions on Evasion Network Generating Hundreds of Millions of Dollars for Quds Force by Oil Sales
On December 8, the US Treasury, sanctioned a wealthy Turkish businessman, his son, 26 companies and an oil tanker belonging to him for violating petroleum sanctions on the Islamic Republic.
According to the OFAC report, Sitki Ayan, a Turkish businessman and the owner of ASB Group of Companies Limited, a Gibraltar-registered holding company, was involved in contracts for selling sanctioned Iranian oil with the cooperation of certain individuals and companies affiliated with him.
Bahaddin Ayan, Sitki Ayan’s son and an ASB Group official, says OFAC, had concluded contracts worth hundreds of million dollars with buyers in China, the United Arab Emirates and Europe and has transferred the proceeds to Quds Force, IRGC’s expeditionary arm.
Sanctioned individuals in this round were Sitki Ayan, his son Bahaddin Ayan, IRGC associate Mustafa Omer Kaptan, who facilitated the equivalent of millions of dollars in payments for oil on behalf of the IRGC, Kasim Oztas, an ASB Group official and close associate of Ayan, and Murat Teke, an employee of Sitki Ayan.
Sanctioned entities include Aktau Petrol Ticaret Anonim Sirketi, Alan Enerji Uretim Sanayi Ve Ticaret Anonin Sirketi, Anatolian Uluslararasi Enerji Yatirim Anonim Sirketi, ASB Grup Enerji Sanayi Ve Ticaret Anonim Sirketi, Aska Enerji Toptan Satis Sanayi Ve Ticaret Anonim Sirketi, Asl Enerji Sanayi Ve Ticaret Anonim Sirketi, Bylan Uluslararasi Ticaret Ve Gayrimenkul Sanayi Anonim Sirketi, Ctat Gida Ve Saglik Urunleri Sanayi Ve Ticaret Anonim Sirketi, Gent Elektrik Enerjisi Toptan Satis Anonim Sirketi, Gent Petrol Ve Dis Ticaret Limited Sirketi, MS Uluslararasi Enerji Yatirim Anonim Sirketi, OGC-Victoria Holding LTD, Perlite Insaat Sanayi Ve Ticaret Anonim Sirketi, Rain Trade Gida IC Ve Dis Ticaret Limited Sirketi, Samed Petrol Ve Enerji Dis Ticaret Limited Sirketi, Somas Enerji Sanayi Ve Ticaret Anonim Sirketi, Som Petrol Ticaret Anonim Sirketi, Som Overseas Petroleum Enerji Sanayi Ve Ticaret Anonim Sirketi and Turang Transit Tasimacilik Anonim Sirketi.
Also sanctioned was the Panamanian-flagged liquefied natural gas tanker Queen Luca.
November 23, 2022: Sanctions on 3 Commanders Involved with the Suppression of Protesters in Sanandaj
On November 23, 2022, in its fourth round of sanctions since the nationwide protests started after the death of Mahsa Amini in September 2022, OFAC added three commanders to its list of violators of human rights.
These commanders were Colonel Hassan Asgari (Asgari), Governor of Sanandaj, the provincial capital of Iranian Kurdistan and a former commander of IRGC, Colonel Alireza Moradi, commander of Sanandaj police, and General Mohammad Taghi Osanloo, the IRGC Ground Forces commander that oversees Iran’s West Azerbaijan province which includes the city of Mahabad.
These three were sanctioned in connection with the brutal suppression of protesters in Kurdish areas. “The Iranian regime is reportedly targeting and gunning down its own children, who have taken to the street to demand a better future,” said Brian E. Nelson. “The abuses being committed in Iran against protestors, including most recently in Mahabad, must stop.”
Like in the case of other sanctioned individuals, announced OFAC in its statement, “all property and interests in property of these persons that are in the United States or in the possession or control of US persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC regulations generally prohibit all dealings by US persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.”
November 17, 2022: Sanctions on 13 Companies in China, Hong King, UAE and Mexico for Violating the Ban on Iranian Petrochemical and Petroleum Sales
On November 17, 2022, OFAC sanctioned a network of 13 companies in China, Hong Kong, and the United Arab Emirates (UAE) for bypassing American sanctions to sell Iranian petroleum and petrochemical products.
According to OFAC, these companies facilitated “the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to buyers in East Asia on behalf of sanctioned Iranian petrochemical brokers Persian Gulf Petrochemical Industry Commercial and Triliance Petrochemical, as well as the National Iranian Oil Company and its marketing arm, Naftiran Intertrade Company Ltd.
The sanctioned firms include Access Technology Trading (Dubai), Asian Zone Trading LLC (UAE), Barza Style & Mode Co. (Hong Kong), East Asia Trading Import and Export Trade Co. (China), Galaxy Petrochemical (UAE), Highline Logistic HK Limited (Hong Kong), Hong Kong Aeonian Complex Co. (Hong Kong), La Nueva Familia Michoacana (Mexico), Monch General Trading LLC (Dubai), Newton Trading FZE (UAE), Sum Five Petrochemicals Trading LLC (UAE), Torgan Co. Limited (Hong Kong), Uteliz Resources Co. Limited (Hong Kong) and Zhejiang Wonder Imp. and Exp. Co. Ltd (China).
The Mexican company La Nueva Familia Michoacana was also indicted by the US Department of Justice for smuggling illicit drugs, especially rainbow fentanyl, into and throughout the United States.
“Today’s action further demonstrates the complex sanctions evasion methods Iran employs to illicitly sell petroleum and petrochemical products,” said Brian E. Nelson. “The United States will continue to implement sanctions against those actors facilitating these sales.”
November 16, 2022: Sanctions on Senior Officials and “Interrogator-Journalists” of Iran’s State-Run Media
On November 16, 2022, the OFAC sanctioned senior officials of the Islamic Republic of Iran Broadcasting (IRIB) and two of its reporters who have become known as “interrogator-journalists”.
These two reporters are Ali Rezaei and Ameneh Sadat Zabihpour, who are known for presenting government propaganda and broadcasting forced confession as “interviews”. The two are accused of working with the Islamic Republic’s security agencies and the IRGC in forcing their targets to confess to bogus crimes on TV.
“The Iranian government’s systemic reliance on forced confessions illustrates the government’s refusal to speak truth to its citizens and the international community,” said Brian E. Nelson. “The United States remains committed to supporting the Iranian people as they continue their peaceful protests. We will continue to hold Iranian officials and government institutions accountable for their human rights violations and their censorship of the Iranian people.”
Also sanctioned were Peyman Jebelli who had been appointed head of IRIB by the Supreme Leader Ali Khamenei, Mohsen Bormahani, deputy director of IRIB, Ahmad Norouzi, head of the IRIB World Service and Yousef Pouranvari, Director of the Programs and Scheduling Department at the same IRIB foreign language flagship channel.
November 15, 2022: Sanctions on Russian and Iranian individuals in Production and Transfer of Iranian Drones to Russia for Use in Ukraine
On November 15, 2022, OFAC added to its sanctions list individuals and entities involved in the production of drones and in transferring them to Russia that Russia has used in devastating attacks against civilian infrastructure in Ukraine.
The sanctioned entities are Shahed Aviation Industries Research Center, the firm responsible for the design and production of Shahed-series UAVs being used by Russian forces in Ukraine, Success Aviation Services FZC and I-Jet Global DMCC, both in Russia, for facilitating the transfer of Iranian UAVs to Russia, Russian Private Military Company “Wagner” (PMC Wagner), Iran’s Islamic Revolutionary Guard Corps Aerospace and Quds Aviation Industries in Iran.
“As we have demonstrated repeatedly, the United States is determined to sanction people and companies, no matter where they are located, that support Russia’s unjustified invasion of Ukraine. Today’s action exposes and holds accountable companies and individuals that have enabled Russia’s use of Iranian-built UAVs to brutalize Ukrainian civilians,” said US Secretary of the Treasury Janet L. Yellen. “This is part of our larger effort to disrupt Russia’s war effort and deny the equipment it needs through sanctions and export controls.”
Also Sanctioned were two individuals for facilitating PMC Wagner’s acquisition of UAVs from Iran, Abbas Djuma and Tigran Khristoforovich Srabionov.
Oct. 26, 2022: Sanctions on 4 Entities and 14 Officials for Ongoing Crackdown on Protests and Internet Censorship
“The United States is committed to supporting the Iranian people and ensuring that those responsible for the brutal crackdown on the ongoing nationwide protests in Iran are held accountable,” US Secretary of State Anthony Blinken said in a statement on October 26, 2022. “Today, we are announcing a joint action between the State and Treasury Departments designating 14 individuals and three entities using five different authorities, demonstrating our commitment to use all appropriate tools to hold all levels of the Iranian government to account.”
Individuals sanctioned were Hedayat Farzadi, Chief Warden of Evin Prison in Tehran, Heshmatollah Hayat Al-Ghaib, Director-General of Tehran Province Prisons, Heidar Pasandideh, warden of Sanandaj Central Prison in Kurdistan province, Murad Fathi, Director-General of Prisons in Kurdistan Province, Mohammad Kazemi, Commander of the Islamic Revolutionary Guards Corps Intelligence Organization (IRGC-IO), Farzin Karimi, Mojtaba Mostafavi and Farzin Karimi, members of Iran’s Intelligence Ministry and co-founders of Ravin Academy that trains individuals in cyber security and hacking, Hossein Modarres Khiabani, Governor of Sistan and Baluchistan province, site of some of the worst violence in the latest round of protests, Morteza Piri, warden of Zahedan Prison, known in Sistan and Baluchistan by prisoners and their families for his brutality toward prisoners, Mohammad Hossein Khosravi, Director-General of Sistan and Baluchistan Province Prisons and former warden of Zahedan Prison, Mohammad Reza Mir-Heydari, Police Commander of Isfahan Province, Abbas Nilforushan, Deputy Commander for Operations of the IRGC, Mohammad Reza Ostad, Warden of Bushehr Prison, and Ahmad Shafahi, Commander of Salman Corps, the IRGC military unit in Sistan and Baluchistan
Entities sanctioned in this round were Bushehr Prison, Ravin Academy and Samaneh Gostar Sahab Pardaz Private Limited Company, one of the main operators of social media filtering services in Iran that actively provides censorship, surveillance, and espionage tools to the government by using big data analysis to analyze the private data of Iranian citizens.
September 14, 2022: Sanctions on IRGC Actors for Their Role in Ransomware Activity, and a $30 Million Prize
On September 14, 2022, OFAC imposed sanctions on 10 individuals and two entities affiliated with the IRGC for their roles in conducting malicious cyber acts, including ransomware activity. These sanctions were part of a joint action with the Department of Justice, Department of State, Federal Bureau of Investigation, US Cyber Command, National Security Agency, and Cybersecurity and Infrastructure Security Agency.
The individuals sanctioned are employees and associates of Najee Technology Hooshmand Fater LLC and Afkar System Yazd Company. Mansour Ahmadi is the owner, managing director, and chairman of the board of Najee Technology, Ahmad Khatibi Aghda is managing director and member of the board of Afkar System. Other sanctioned individuals are employees and associates of Najee Technology and/or Afkar System: Ali Agha-Ahmadi, Mohammad Agha Ahmadi, Mo’in Mahdavi, Aliakbar Rashidi-Barjini, Amir Hossein Nikaeen Ravari, Mostafa Haji Hosseini, Mojtaba Haji Hosseini and Mohammad Shakeri-Ashtijeh.
The sanctioned entities are Najee Technology Hooshmand Fater LLC and Afkar System Yazd Company, both affiliated with the IRGC.
According to OFAC’s statemen, some of the malicious cyber activities of these individuals and entities “can be partially attributable to several named intrusion sets, such as ‘APT 35,’ ‘Charming Kitten,’ ‘Nemesis Kitten,’ ‘Phosphorus,’ and ‘Tunnel Vision’. Several cybersecurity firms have determined these intrusion sets as being associated with the Iranian government, and have identified them as having conducted a varied range of malicious cyber-enabled activities, including ransomware and cyber-espionage.
It was also announced that, under the US State Department’s program Rewards for Justice, administered by the State Department’s Bureau of Diplomatic Security, a reward of up to $10 million dollars has been set for information leading to the arrest of each one the three following sanctioned individuals: Mansour Ahmadi, owner of Najee Technology Hooshmand Fater, Ahmad Khatibi Aghda, managing director of Afkar System Yazd Company, and Amir Hossein Nikaeen Ravari.
All three are wanted for their alleged involvement in a coordinated campaign that compromised hundreds of computer networks across the United States and in other countries. Between October 2020 and August 2022, they allegedly gained unauthorized access to protected networks, exfiltrated data, encrypted computer systems, and extorted victims for ransom, causing damage to and disrupting operations of organizations across multiple sectors, including critical infrastructure, government agencies, and non-profit organizations.
One of the charges against these individuals and group is a cyber attack on a children’s hospital: “In June 2021, the group gained unauthorized access to supervisory control and data acquisition systems associated with a US-based children’s hospital. Once the group compromised the network, they created unauthorized accounts, escalated privileges, moved laterally through the network, established persistent access, exfiltrated data, and encrypted at least one device with BitLocker. US government law enforcement partners provided a notification to the children’s hospital before there were any impacts to patient care or medical services.”
“Ransomware actors and other cybercriminals, regardless of their national origin or base of operations, have targeted businesses and critical infrastructure across the board—directly threatening the physical security and economy of the United States and other nations,” said Brian E. Nelson. “We will continue to take coordination action with our global partners to combat and deter ransomware threats, including those associated with the IRGC.”
September 22, 2022: Sanctions on the Morality Police and Senior Security Officials for the Death of Mahsa Amini
On September 22, 2022, after the death of 22-year-old Mahsa Amini in the custody of Morality Police, the OFAC sanctioned the morality police and seven individuals for abuse and violence against Iranian women and the violation of the rights of peaceful Iranian protestors.
The individuals added to the Treasury’s list of human rights violators were Mohammad Rostami Cheshmeh Gachi, head of Iran’s Morality Police, Haj Ahmad Mirzaei, head of the Tehran division of Iran’s morality police during Amini’s detention and death, Esmail Khatib, Iran’s Minister of Intelligence, Salar Abnoush, deputy commander of the IRGC-affiliated Basij paramilitary forces who have been linked to the killing of unarmed protestors on numerous occasions, Qasem Rezaei, Deputy Commander of National Police, Manouchehr Amanollahi, police commander of Iran’s Chaharmahal and Bakhtiari province, and Kiumars Heidari, commander of the Iranian Army’s Ground Forces who has publicly admitted to his and his force’s involvement in the violent response to the November 2019 protests that led to the death of hundreds of protesters.
Minister of Intelligence Esmail Khatib appears on various US sanctions lists against the Islamic Republic. OFAC’s press release states that the Ministry of Intelligence is one of the Iranian government’s main security services which is responsible for serious human rights abuses. Under his leadership, the ministry has cracked down on a large number of human rights defenders, women-rights activists, journalists, filmmakers, and members of religious minority groups. The Ministry of Intelligence has also aggressively persecuted individuals reporting on human rights abuses and violations in Iran, as well as their families, and subjected detainees to torture in secret detention centers during his tenure.
Sepember 29, 2022: Sanctions on 10 Companies Involved in Selling Sanctioned Iranian Petroleum and on a Panamanian-Flagged Oil Tanker
In an update to US sanctions on September 29, 2022, OFAC announced that the US Treasury had sanctioned a number of companies based in the United Arab Emirates, Hong Kong and India involved in the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to end users in South and East Asia.
According to OFAC, Triliance Petrochemical and Persian Gulf Petrochemical Industry Commercial Co. played the role of brokers in transferring funds and shipping Iranian petroleum and petrochemicals to buyers in Asia and were also involved in currency exchanges related to these exports.
Triliance also utilized front companies to pay UAE-based Clara Shipping LLC millions of dollars in freight charges for the shipment of Iranian petrochemical and petroleum products to East Asia. Triliance purchased millions of dollars of Iranian petrochemical and petroleum products from Iran-based petrochemical broker Middle East Kimiya Pars Company. Both companies were sanctioned as well.
Also sanctioned was Gas Allure, a Panamanian-flagged oil tanker which transported tens of thousands of metric tons of Iranian petrochemicals brokered by Triliance.
“The United States is committed to severely restricting Iran’s illicit oil and petrochemical sales,” said Brian E. Nelson. “So long as Iran refuses a mutual return to full implementation of the Joint Comprehensive Plan of Action, the United States will continue to enforce its sanctions on the sale of Iranian petroleum and petrochemical products.”
September 19, 2022: Sanctions on Iranian Cargo Planes that Violate Sanctions on Russia
On September 19, 2022, the US Commerce Department, through its Bureau of Industry and Security (BIS), sanctioned the fourth Iranian-owned and -operated cargo plane that had flown into Russia in violation of sanction on that country.
“Our expansive controls, especially on items such as electronics and aircraft parts, have degraded Russia’s defense industrial base, severely restricted their access to the world economy, and isolated them from the international community,” said Assistant Secretary of Commerce for Export Enforcement Matthew S. Axelrod. “When Russia seeks to engage pariah states like Iran in order to backfill for what the international community has cut off, we will take action to thwart such attempts and disrupt such connections.”
The sanctioned aircrafts were operated by Mahan Air, Qeshm Fars Air, and Iran Air.
October 6, 2022: Sanctions on Ministers of Interior and Communications and 5 Security Officials Responsible for Internet Shutdown and Violent Crackdown on Peaceful Protests
On October 6, 2022, at the end the third week of nationwide protests after the death of Mahsa Amini in the custody of the Morality Police, US Commerce Department added Islamic Republic’s ministers of interior and communications and five security officials to its list of violators of human rights.
Sanction ministers were:
— Iran’s Minister of the Interior General Ahmad Vahidi, who maintains oversight over all Law Enforcement Forces (LEF or the National Police ) deployed to subdue protests in Iran, including the ongoing protests over the death of Mahsa Amini: “The LEF has used lethal force against protesters on multiple occasions in the past, making it a key instrument of the Iranian regime in its ongoing repression of its own people. The LEF’s actions have resulted in thousands of deaths, including at least dozens of casualties in the recent demonstrations against the morality police.”
— Eisa Zaerpour, Minister of Communications, responsible for the Iranian government’s attempts to block the Internet access of millions of Iranians in the hopes of slowing down the protests.
Sanctioned senior security officials were Hossein Sajedinia, the Deputy Operations Commander of the LEF, Yadollah Javani, the Deputy Political Commander of the IRGC, Vahid Mohammad Naser Majid, the head of the Iranian Cyber Police, Hossein Nejat, an IRGC commander, a close associate of Iran’s Supreme Leader and the head of Sarallah base, the IRGC’s security apparatus based in Tehran, and Hossein Rahimi, the Tehran police chief who oversees much of the morality police’s hijab compliance enforcement in the capital.
This action followed the September 22 designation of Iran’s morality police, its senior leadership, and other senior leaders of Iran’s security organizations.
“The rights to freedom of expression and of peaceful assembly are vital to guaranteeing individual liberty and dignity,” said Brian Nelson. “The United States condemns the Iranian government’s Internet shutdown and continued violent suppression of peaceful protest and will not hesitate to target those who direct and support such actions.”
August 9, 2022: Sanctions on the China’s Far East Cable Company for Violating Sanctions against Iran
On August 9, 2022, the US Commerce Department sanctioned Far East Cable, China's largest wire and cable manufacturer, for violating US export controls related to shipments of telecommunications equipment to Iran.
Far East Cable entered into an agreement in 2013 to buy equipment from Chinese telecommunications equipment maker ZTE Corporation and then contracted with Iranian companies to supply telecommunications equipment and parts, said the Commerce Department that accused Far East Cable of 18 violations of US export controls between September 2014 to January 2016.
According to the US Commerce Department, Far East Cable contracted with the Telecommunications Company of Iran (TCI) and Khadamate Ertebati Rightel, another Iranian company, in 2014. Both were customers of ZTE, which suspended shipments of US-origin items to Iran in 2012, after it was reported that the company had contracted to ship goods from American companies to TCI, despite US sanctions on Iran. But the following year, despite a Commerce Department probe, ZTE made plans to resume shipments to Iran via the third party.
“As alleged, Far East Cable acted as a cutout for ZTE, facilitating ZTE shipments to Iran at the very time ZTE knew it was under investigation for the exact same conduct," John Sonderman, a Commerce Department official, said in a statement.
September 8, 2022: Sanctions on 4 Iranian Companies and an Iranian National Involved in Production of Drones and Weapon Shipment to Russia
On September 8, 2022, OFAC sanctioned four Iranian companies and an Iranian national for research, development, production, procurement and shipment of Iranian UAVs and UAV components, including the Shahed series of drones sent to Russia for its war against Ukraine.
The sanctioned companies were:
— Tehran-based Safiran Airport Services, coordinated Russian military flights between Iran and Russia, including those associated with transporting Iranian UAVs, personnel, and related equipment from Iran to Russia.
— Paravar Pars Company, closely associated with IRGC-controlled Imam Hossein University, produced UAVs for the IRGC ASF and has tested UAVs for the IRGC Navy. In particular, Paravar Pars Company was involved in the research, development, and production of the Iranian Shahed-171 UAV developed by the IRGC Aerospace Force (IRGC-ASF).
— Design and Manufacturing of Aircraft Engines (DAMA), an Iranian company involved in the research, development, and production of the Iranian Shahed-171 UAV program, which is owned by the IRGC-ASF. DAMA is a front company that carried out covert procurement activities for Iran’s Aircraft Manufacturing Industries (HESA).
— Baharestan Kish Company, which oversaw various defense-related projects, including the manufacturing of UAVs
The individual sanctioned is Rahmatollah Heidari, Baharestan Kish Company’s managing director and a member of its board of directors who has been involved with various aspects of the company’s operation to include securing facilities for the company.
“Russia is making increasingly desperate choices to continue its unprovoked war against Ukraine, particularly in the face of our unprecedented sanctions and export controls,” said Brian E. Nelson. “The United States is committed to strictly enforcing our sanctions against both Russia and Iran and holding accountable Iran and those supporting Russia’s war of aggression against Ukraine. We will also not hesitate to target producers and procurers who contribute to Iran and its IRGC’s UAV program”
Earlier, US National Security Adviser Jake Sullivan had said that the Islamic Republic government was preparing to send “several hundred” drones, including some equipped with weapons, to Russia.
September 9, 2022, US Sanctions Islamic Republic’s Intelligence Ministry and Intelligence Minister for “Malign” Cyber Activities
On September 9, 2022, OFAC sanctioned the Islamic Republic’s Ministry of Intelligence and Esmail Khatib, Ebrahim Raisi’s Intelligence Minister, for involvement in cyber attacks against the US and American allies.
According to OFAC, since at least 2007, the Intelligence Ministry and its cyber actor proxies have conducted malicious cyber operations targeting a range of government and private-sector organizations around the world and across various critical infrastructure sectors. In July 2022, cyber threat actors, assessed to be sponsored by the government of Iran and its Ministry of Intelligence, disrupted Albanian government computer systems, forcing the government to suspend online public services for its citizens.
Under the leadership of Esmail Khatib, announced OFAC, Iran’s Intelligence Ministry directs several networks of cyber threat actors involved in cyber espionage and ransomware attacks in support of Iran’s political goals. In addition to conducting malicious cyber activities that affected Albanian government websites, Ministry of Intelligence cyber actors were also responsible for leaking documents purported to be from the Albanian government and personal information associated with Albanian residents.
A day earlier, NATO had condemned the cyber attack on Albania, a member of the alliance. "We strongly condemn such malicious cyber activities designed to destabilize and harm the security of an ally, and disrupt the daily lives of citizens," the North Atlantic Council, a group of representatives of NATO's 30 member states, said in a statement. And a day before that, Albania had broken diplomatic relations with Tehran and had given its diplomats 24 hours to close the embassy and leave the country.
“Iran’s cyber-attack against Albania disregards norms of responsible peacetime State behavior in cyberspace, which includes a norm on refraining from damaging critical infrastructure that provides services to the public,” said Brian E. Nelson. “We will not tolerate Iran’s increasingly aggressive cyber activities targeting the United States or our allies and partners.”
August 1, 2022: Sanctions on 6 Companies in UAE, Malaysia, Singapore and China and on a Tanker Connected to the Sale of Iranian Petroleum
On August 1, 2022, the OFAC took action against companies used by Iran’s Persian Gulf Petrochemical Industry Commercial Company (PGPICC), one of the nation’s largest petrochemical brokers, to facilitate the sale of tens of millions of dollars’ worth of Iranian petroleum and petrochemical products from Iran to East Asia. PGPICC is a subsidiary of Iran’s petrochemical conglomerate Persian Gulf Petrochemical Industry Co. (PGPIC), which accounts for half of all of Iran’s total petrochemical exports.
“The United States continues to pursue the path of diplomacy to achieve a mutual return to full implementation of the Joint Comprehensive Plan of Action [JCPOA, the nuclear deal],” said Brian E. Nelson. “Until such time as Iran is ready to return to full implementation of its commitments, we will continue to enforce sanctions on the illicit sale of Iranian petroleum and petrochemicals.”
On August 2, in reaction to these sanctions, Iran’s Foreign Minister Hossein Amir Abdollahian said: “I would like to point out that in response to this American action, Iran injected hexafluoride gas into hundreds of new generation centrifuges … They must put aside exaggeration, as we are people of logic and negotiation, and we are serious about reaching a strong agreement, but if the American side wants to continue this path, our hands will never be tied.”
Sanctioned companies were UAE-based Blue Cactus Heavy Equipment and Machinery Spare Parts Trading LLC for its dealings with Iran’s PGPICC, China-based Farwell Canyon HK Ltd, China-based Golden Warrior Shipping, Pioneer Shipmanagement PTE Ltd in Singapore, Malaysia-based PZNFR Trading Limited and Shekufei International Trading Ltd in Hong Kong.
Also sanctioned was the Panamanian-flagged tanker Glory Harvest for working with Golden Warrior Shipping Company in its activities to bypass the export of Iranian petroleum and petrochemicals.
June 16, 2022: Sanctions on Indian and Chinese Nationals and the International Sanctions Evasion Network Supporting Iranian Petrochemical Sales in Iran, China, UAE and Hong Kong
On June 16, 2022, OFAC announced that it had sanctioned a network of Iranian petrochemical producers, as well as front companies in China and the United Arab Emirates (UAE) that support Iran’s Triliance Petrochemical Ltd. and Iran’s Petrochemical Commercial Company (PCC), “entities instrumental in brokering the sale of Iranian petrochemicals abroad. This network helps effectuate international transactions and evade sanctions, supporting the sale of Iranian petrochemical products to customers in the China and the rest of East Asia.”
“The United States is pursuing the path of meaningful diplomacy to achieve a mutual return to compliance with the Joint Comprehensive Plan of Action [the nuclear deal]. Absent a deal, we will continue to use our sanctions authorities to limit exports of petroleum, petroleum products, and petrochemical products from Iran,” said Brian E. Nelson. “The United States will continue to expose the networks Iran uses to conceal sanctions evasion activities.”
The companies sanctioned were Iran-based Marun Petrochemical Company, a commercial supplier of petrochemicals to Triliance Co., Iran-based Kharg Petrochemical Company Ltd which has sold Triliance tens of thousands of metric tons of Iranian petrochemicals, Iran-based Fanavaran Petrochemical Company which has sold Iranian petrochemicals including methanol, valued in the tens of millions of dollars, Hong Kong-based Keen Well International Limited that was used to process payments on behalf of Triliance for the shipment of Iranian naphtha, valued in the millions of dollars, to Singapore, Hong Kong-based Triliance front company Teamford Enterprises Limited which facilitated transactions on behalf of Triliance involving the shipment of Iranian sourced petrochemicals to East Asia, and UAE-based front companies GX Shipping FZE that has concealed the source of Iranian petrochemicals in order to further Triliance’s business and evade sanctions, Future Gate Fuel and Petrochemical Trading L.L.C. that was used to conceal Triliance’s involvement in the purchase of Iranian petrochemicals valued at more than $10 million, Sky Zone Trading FZE which concealed Triliance’s involvement in petrochemical transactions and purchased over $10 million worth of Iranian petrochemicals on behalf of Triliance, and Youchem General Trading FZE that has concealed Triliance’s involvement in petrochemical transactions and received payments on behalf of Trio Energy DMCC, a sanctioned Triliance front company.
Sanctioned individuals were Jingfeng Gao, also known as Jeff Gao, a China-based broker for Triliance who has been involved in multi-million-dollar transactions for Iranian petrochemicals on behalf of Triliance, and Mohammad Shaheed Ruknooddin Bhore, an India-based Indian national who manages multiple Triliance front companies.
July 6, 2022: Sanctions on 2 Iranians and Companies in UAE, Iran and Hong Kong for Bypassing Sanctions on the Sale of Iranian Petroleum
On July 6, 2023, OFAC sanctioned an international network of individuals and entities that used a web of Gulf-based front companies to facilitate the delivery and sale of hundreds of millions of dollars’ worth of Iranian petroleum and petrochemical products from Iranian companies to East Asia.
Concurrently with US Treasury sanctions designations, the US Department of State imposed sanctions on five entities based in Iran, Vietnam, and Singapore.
“While the United States is committed to achieving an agreement with Iran that seeks a mutual return to compliance with the Joint Comprehensive Plan of Action [the nuclear deal], we will continue to use all our authorities to enforce sanctions on the sale of Iranian petroleum and petrochemicals,” said Brian E. Nelson.
The two sanctioned Iranian nationals are Morteza Rajabi-Eslami and Mahdieh Sanchuli who have partnered to export Iranian crude oil and petrochemical products on behalf of Switzerland-based Naftiran Intertrade Company, the marketing arm of the National Iranian Oil Company. Rajabi-Eslami owns an extensive network of companies engaged in refining, energy trading, shipping, and bunkering, which have facilitated the shipment of thousands of metric tons of fuel oil worth millions of dollars from Iran. These companies have been involved in contracts valued in the tens of millions of dollars related to the sale of petroleum products from Iran.
Sanctioned companies include Jam Petrochemical Company (Iran) which has exported hundreds of thousands of metric tons of petrochemical products, worth hundreds of millions of dollars, to companies throughout East Asia, Edgar Commercial Solutions FZE (UAE) that has purchased and exported hundreds of millions of dollars of petrochemical products from numerous sanctioned Iranian companies, East Ocean Rashin Shipping Co. (Iran), Zagros Tarabaran-e Arya (Iran), Ali Al- Mutawa Petroleum & Petrochemical Trading LLC (UAE), Persian Gulf Star Oil Company (Iran), Truong Phat Loc Shipping Trading Joint Stock Company (Vietnam), Everwin Shipmanagement Ltd (Singapore) and Oligei International Trading Co. (Hong Kong).
May 25, 2022: Sanctions on Oil Smuggling and Money Laundering Network Generating Hundreds of Millions of Dollars for Iran’s IRGC and Quds Force and Lebanese Hezbollah
On May 25, 2022, OFAC targeted an international oil smuggling and money laundering network led by IRGC’s expeditionary Quds Force officials that facilitated the sale of hundreds of millions of dollars’ worth of Iranian oil for both the Quds Force and Lebanese Hezbollah.
Properties and assets of individuals and entities in this round of sanctions in the US, if any, were blocked and the individuals were banned from entering the US.
Sanctions on individuals involved in oil smuggling and money laundering network:
According to the US Department of Treasury, this oil smuggling network, led by the US-sanctioned Quds Force official Behnam Shahriari and former Quds force official Rostam Ghasemi and backed by senior levels of the Russian Federation government and state-run economic organs, has acted as a critical element of Iran’s oil revenue generation, as well as its support for proxy militant groups that continue to perpetuate conflict and suffering throughout the region.
Individuals sanctioned in connection with the network of oil smuggling and money laundering were Bahnam Shahriari, a Quds Force official, Turkey-based IRGC-QF associates Hakki Selcuk Sanli, Abdulhamid Celik and Seyyid Cemal Gunduz who worked with Shahriari to conceal the source of proceeds from illicit Iranian oil and petrochemical sales, Iran-based IRGC associate Esam Ettehadi who assisted in brokering and finalizing oil deals in the interest of the IRGC, Mihrab Suhrab Hamidi, an Afghan national who resides in Russia, Iran-based Quds Force associates Mohammad Sadegh Karimian and Alireza Kashani-Mehr who facilitated the illicit sale of Iranian oil for the Quds Force, Turkey-based Abdulaziz Kaskariy, Iran-based Azim Monzavi, an IRGC official who facilitates oil sales on behalf of the IRGC, and Kamaluddin Gulam Nabizada, an dual national Afghan-Russian businessman involved in transferring millions of dollars on behalf of the Quds Force from Russia.
Sanctions on companies involved in oil smuggling and money laundering network:
Companies sanctioned in connection with the network of oil smuggling and money laundering were Hong Kong-based energy company China Haokun Energy Limited, a subsidiary of Beijing-based Haokun Energy Group Company Limited, that has purchased millions of barrels of Iranian oil from the Quds Force, valued at tens of millions of dollars, Lebanon-based Concepto Screen SAL Off-Shore that Hezbollah officials, including Muhammad Qasim al-Bazzal and Muhammad Qasir, have used to facilitate oil deals likely benefiting the Quds Force and Hezbollah, Iran-based Petro China Pars, a joint venture between Iranian and China-based energy companies, China-based Fujie Petrochemical Zhoushan, China-based Shandong Sea Right Petrochemical, South Korea-based Turkoca Import-Export Transit and UAE-based Zamanoil DMCC that has worked with the Russian government and Russian state-owned Rosneft to ship large quantities of Iranian oil to companies in Europe on behalf of the IRGC’s Quds Force.
“The United States remains fully committed to holding the Iranian regime accountable for its support to terrorist proxies that destabilize the Middle East,” said Brian E. Nelson. “While the United States continues to seek a mutual return to full implementation of the Joint Comprehensive Plan of Action, we will not hesitate to target those who provide a critical lifeline of financial support and access to the international financial system for the Quds Force or Hezbollah. In particular, the United States will continue to strictly enforce sanctions on Iran’s illicit oil trade. Anyone purchasing oil from Iran faces the prospect of US sanctions.”
The Russian government, the IRGC and the Quds Force and sanctioned Iranian petroleum exports:
As early as April 2021, former Quds Force official Rostam Ghasemi leveraged Russia-based RPP Limited Liability Company, formerly managed by Afghan businessman Kamaluddin Gulam Nabizada, to transfer millions of dollars on behalf of the Quds Force from Russia.
According to the US Treasury, Nabizada, the former Afghan chargé d’affaires in Moscow, raised funds for the Quds Force in coordination with senior levels of the Russian government and intelligence apparatus. Russia-based Nabizada has previously been linked to a corrupt scheme to defraud the Afghanistan-based Kabul Bank, resulting in the widespread loss of confidence in the Afghan banking sector and the loss of more than $800 million to the Afghan government and its people.
Mihrab Suhrab Hamidi is the current manager of RPP Limited Liability Company. Some of the oil sales and transport to which RPP LLC was a party while Hamidi was manager were overseen by Rostam Ghasemi.
UAE-based Zamanoil DMCC has also worked with the Russian government and Russian state-owned Rosneft to ship large quantities of Iranian oil to companies in Europe on behalf of the Quds Force.
Quds Force facilitators & negotiators:
According to OFAC, Iran-based Quds Force associates Mohammad Sadegh Karimian and Alireza Kashani-Mehr helped to facilitate the illicit sale of Iranian oil for the Quds Force. Both have traveled from Iran to Turkey and have worked with Shahriari’s network to conceal the source of the proceeds from these sales. Additionally, Karimian, with the assistance of Nabizada, arranged the sale and transport of tens of thousands of tons of oil on behalf of senior Quds Force officials Shahriari and Ghasemi.
Iran-based Azim Monzavi is an IRGC official who facilitates oil sales on behalf of the IRGC. Monzavi has worked with Shahriari to facilitate payments for oil from Venezuelan state-owned oil and natural gas company, PDVSA.
Iran-based IRGC associate Esam Ettehadi has assisted in brokering and finalizing oil deals in the interest of the IRGC, some of which were customers in China and Russia. Monzavi and Ettehadi have both brokered and finalized oil deals in coordination with Shahriari and Ghasemi.
IRGC’s money laundering network in Turkey:
Turkey-based IRGC associates Hakki Selcuk Sanli, Abdulhamid Celik, and Seyyid Cemal Gunduz have worked with Shahriari to conceal the source of proceeds from illicit Iranian oil and petrochemical sales. These transactions include the sale of Iranian petrochemicals worth more than $6 million. Sanli, Celik and Gunduz also concealed the transfer and sale of millions of dollars’ worth of gold and its equivalent in cash on behalf of the IRGC.
Sanli co-founded an IRGC-associated extremist organization known as Tawhid-Salam in the 1990s, of which Celik was also a member. Tawhid-Salam received funding through close collaboration with IRGC finance officials operating in Turkey. Sanli and Celik served prison sentences in Turkey for their roles in the murder of two opponents of the Iranian government. Celik also worked with Tawhid-Salam, supplying a bomb for a 2011 attack in Istanbul which injured several people.
December 16, 2021: Sanctions on 37 Entities in Connection with Biotechnology Weapons
On December 16, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) imposed sanctions on 37 companies in China, Malaysia, Republic of Georgia and Turkey and accused them of violating sanctions on Iran’s military programs.
BIS announced that the sanctions were “to address the ongoing threats to US national security and foreign policy presented by the People’s Republic of China (PRC)’s efforts to develop and deploy biotechnology and other technologies for military applications and human rights abuses. BIS is also taking action against entities operating in the PRC, Georgia, Malaysia, and Turkey for diverting or attempting to divert US items to Iran’s military programs.”
“The scientific pursuit of biotechnology and medical innovation can save lives. Unfortunately, the PRC [China] is choosing to use these technologies to pursue control over its people and its repression of members of ethnic and religious minority groups. We cannot allow US commodities, technologies, and software that support medical science and biotechnical innovation to be diverted toward uses contrary to US national security,” said US Secretary of Commerce Gina M. Raimondo. “The US will continue to stand strong against efforts by the PRC and Iran to turn tools that can help humanity prosper into implements that threaten global security and stability.”
December 7, 2021: Sanctions on 2 Branches of Iranian Military and 2 Prisons in Connection with November 2019 Nationwide Protests
On December 7, 2021, OFAC imposed sanctions on Special Units of Iran’s National Police, Iran’s Counter-Terror Special Forces (NOPO), Isfahan Central Prison and Zahedan Prison for violating human rights.
OFAC said that, during November 2019 nationwide protests, Police Special Units and NOPO used excessive and lethal force, firing upon unarmed protestors, including women and children, with automatic weapons. NOPO forces blocked main streets with armed vehicles and fired randomly at crowds with heavy machine guns.
Sanctioned individuals who were involved in the bloody suppression of November 2019 nationwide protests were Hassan Karami, the commander of the Police Special Units who has overseen these units during periods of nationwide unrest, Mohsen Ebrahimi, commander of NOPO since 2016 and who has similarly overseen the unit during several subsequent periods of nationwide unrest, Seyed Reza Mousavi Azami, commander of a brigade of Police Special Units, Gholamreza Soleimani, commander of IRGC-affiliated paramilitary Basij, one of Iran’s most important domestic security resources, Leila Vaseghi, the governor of Quds city who was responsible for issuing an order to the police and other armed forces during the November 2019 protests to shoot unarmed protestors, IRGC interrogators Ali Hemmatian and Masoud Safdari who have long records of physical abuse against Iranian political prisoners at IRGC detention facilities, including at Iran’s Evin Prison.
Also sanctioned were Soghra Khodadadi, director of Qarchak Women’s Prison, who was responsible for ordering and directly participating in a violent attack on December 13, 2020 against prisoners of conscience in Ward 8 along with at least 20 other guards, and Mohammad Karami, a Brigadier General who commands the IRGC South-East Quds Operational Base in Zahedan in Sistan and Baluchistan province and was responsible for the actions of IRGC officers stationed at the Shamsar Base who, according to Amnesty International on February 22, 2021, fired live ammunition at unarmed fuel carriers who were seeking to exercise their freedom of expression.
November 18, 2021: Sanctions on Iran Cyber Actors for Attempting to Influence the 2020 US Presidential Election
On November 18, 2021, OFAC sanctioned six Iranian individuals and one Iranian entity for attempting to influence the 2020 presidential election.
“Between approximately August 2020 and November 2020, state-sponsored Iranian cyber actors executed an online operation to intimidate and influence American voters, and to undermine voter confidence and sow discord, in connection with the 2020 US presidential election,” OFAC announced. “These Iranian actors obtained or attempted to obtain US voter information from US state election websites, sent threatening emails to intimidate voters, and crafted and disseminated disinformation pertaining to the election and election security. Furthermore, the Iranians illicitly accessed content management accounts of several online US media entities, which resulted in their ability to edit and create fraudulent content. However, the actors’ ability to leverage this unauthorized access was ultimately thwarted by the Federal Bureau of Investigation (FBI).”
The sanctioned Iranian company was Iman Net Pasargad that, according to OFAC, led this attempted election influence campaign. This company had been sanctioned before when it operated under the name of Net Peygard Samavat Company, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Islamic Revolutionary Guard Corps-Electronic Warfare and Cyber Defense Organization (IRGC-EWCD). The company rebranded itself to evade US sanctions and to continue its disruptive operations against the United States.
Sanctioned individuals were Iman Net Pasargad’s CEO Mohammad Bagher Shirinkar, employees Seyyed Mohammad Hossein Musa Kazemi and Sajjad Kashian, who executed cyber-enabled operations as part of the campaign to influence the election and members of the company’s board of directors Mostafa Sarmadi, Seyyed Mehdi Hashemi Toghroljerdi, and Hossein Akbari Nodeh.
On the same day, the US Department of Justice unsealed a five-count indictment against Seyyed Mohammad Hossein Musa Kazemi and Sajjad Kashian, offering a reward of up to $10 million for information on or about the activities of these two individuals. “As alleged, Kazemi and Kashian were part of a coordinated conspiracy in which Iranian hackers sought to undermine faith and confidence in the US presidential election,” said U.S. Attorney Damian Williams for the Southern District of New York.
October 29, 2021: Sanctions on Network and Individuals in Connection with Iran’s Drone Program
On October 29, 2021, OFAC sanctioned members of a network of companies and individuals that have provided critical support to the Unmanned Aerial Vehicle (UAV) programs of Iran’s Islamic Revolutionary Guard Corps (IRGC) and its expeditionary unit Quds Force.
Sanctioned individuals were IRGC Brigadier General Saeed Aghajani, who oversees the IRGC’s UAV Command and directs the planning, equipment, and training for IRGC UAV operations, IRGC Brigadier General Abdollah Mehrabi, chief of the IRGC Aerospace Force Research and Self-Sufficiency Jihad Organization, Yousef Aboutalebi, Managing Director of Oje Parvaz Mado Nafar Company that procures UAV engines for the IRGC Navy and entities supporting weapons development for the Iranian military, and Mohammad Ebrahim Zargar Tehrani of Kimia Part Sivan Company that has worked with the Quds Force to improve the force’s UAV program.
Also sanctioned were the two companies Oje Parvaz Mado Nafar and Kimia Part Sivan.
“Iran’s proliferation of UAVs across the region threatens international peace and stability. Iran and its proxy militants have used UAVs to attack US forces, our partners, and international shipping,” said Deputy Secretary of the Treasury Wally Adeyemo. “Treasury will continue to hold Iran accountable for its irresponsible and violent acts.”
September 17, 2021: Sanctions on a Money Laundering Network in Support of Lebanese Hezbollah and the Quds Force
On September 17, 2021, OFAC sanctioned members of a network of Lebanon- and Kuwait-based financial conduits that fund Lebanese Hezbollah. Additionally, OFAC sanctioned members of an international network of financial facilitators and front companies that operate in support of Hezbollah and Iran’s Quds Force.
“Together, these networks have laundered tens of millions of dollars through regional financial systems and conducted currency exchange operations and trades in gold and electronics for the benefit of both Hezbollah and the IRGC-QF [Quds Force],” announced OFAC. “Hezbollah, with the support of the IRGC-QF, uses the revenues generated by these networks to fund terrorist activities, as well as to perpetuate instability in Lebanon and throughout the region.”
“Hezbollah and the IRGC-QF continue to exploit the international financial system to finance acts of terrorism,” said Office of Foreign Assets Control Director Andrea M. Gacki. “The United States will not hesitate to take action to disrupt networks that provide financial support to Hezbollah and IRGC-QF.”
According to OFAC, China-based Iranian businessman Morteza Minae Hashemi has used his access to the international financial system to launder vast sums of money for the IRGC-QF and Hezbollah. In coordination with Mohammad Reza Kazemi, Hashemi has laundered tens of millions of dollars for the IRGC-QF and Hezbollah through foreign currency conversions and gold sales.
Hashemi is aided by People’s Republic of China nationals Yan Su Xuan and Song Jing who, at the direction of Hashemi, have helped him establish bank accounts and serve as straw owners for his companies. Yan Su Xuan, on Hashemi’s behalf, has also purchased US-origin, dual-use products for onward shipment to Iran.
Also sanctioned is Hasib Muhammad Hadwan, also known as Hajj Zayn, a senior official in Hezbollah’s General Secretariat. He is subordinate to Hezbollah’s Secretary General, Hassan Nasrallah, and is responsible for raising funds from donors and businessmen outside Lebanon. Ali al-Sha’ir is Hadwan’s office manager and has been accepting financial contributions on behalf of Hezbollah since 2000.
Talib Husayn ‘Ali Jarak Ismai’l coordinated the transfer of millions of dollars to Hezbollah from Kuwait through Jamal Husayn ‘Abd ‘Ali ‘Abd-al-Rahim al-Shatti.
Sanctioned Iranian national in Lebanese Hezbollah’s money laundering network are Mohammad Ali Damirchilu, Samaneh Damirchilu and Omid Yazdanparast Mohammad who facilitate the smuggling of gold and currency from Iran to Turkey and Reza Kazemi who facilitates the gold sales in Turkey.
Mostafa Puriya and Hossein Asadollah sell electronics on behalf of this network in the UAE through the Dubai-based company Hemera Infotech FZCO.
Meghdad Amini and Ali Qasir run a network of nearly 20 individuals and front companies, located in multiple countries and jurisdictions, that facilitates the movement and sale of tens of millions of dollars’ worth of gold, electronics, and foreign currency in support of Hezbollah and the Quds Force.
September 3, 2021: Sanctions on Intelligence Operative for Attempting to Kidnap Journalist Masih Alinejad
On September 3, 2021, OFAC sanctioned four Iranian intelligence operatives who plotted to kidnap Masih Alinejad, the Iranian journalist and women’s rights activist who resides in the US.
The four operatives were Alireza Shahvaroghi Farahani, Mahmoud Khazein, Kiya Sadeghi, and Omid Noori: “Senior Iran-based intelligence official Alireza Shahvaroghi Farahani leads a network of intelligence operatives, including Mahmoud Khazein, Kiya Sadeghi, and Omid Noori, tasked with targeting Iranian dissidents in the United States, the United Kingdom, Canada, and the United Arab Emirates. Farahani, Khazein, Sadeghi, and Noori planned the abduction of a New York City-based Iranian-American activist by utilizing the services of a private investigator to conduct surveillance on the victim and laundered money from Iran to the United States to pay for this surveillance.
“Sadeghi acted as the network’s primary point of contact with the private investigator in the United States and researched options to abduct the victim via military-style speedboats out of New York City for transport to Venezuela. Noori facilitated payment to the investigator, while Khazein researched travel routes from the victim’s residence to potential exfiltration points.
“Farahani, Khazein, Sadeghi, and Noori have been indicted in the US District Court for the Southern District of New York for conspiracy related to kidnapping, sanctions violations, bank and wire fraud, and money laundering.”
Neither OFAC’s statement nor the indictment, however, identify Masih Alinejad by name.
“The Iranian government’s kidnapping plot is another example of its continued attempt to silence critical voices, wherever they may be,” said Director of the Office of Foreign Assets Control, Andrea M. Gacki. “Targeting dissidents abroad demonstrates that the government’s repression extends far beyond Iran’s borders.”
“Iran’s attempt to kidnap a US citizen on U.S. soil because she used her freedom of speech to criticize the Iranian government is unacceptable and an egregious violation of fundamental international norms,” said Secretary of State Antony Blinken in a statement. “Beyond this specific plot, the United States remains aware of ongoing Iranian interest in targeting other American citizens, including current and former US officials … we will not tolerate efforts to intimidate independent journalists or silence their voices. We will hold those responsible to account. And we will not tolerate any attacks on US citizens, here or abroad.”
August 13, 2021: Sanctions on Oil Broker Network Supporting Quds Force
On August 13, 2021, OFAC sanctioned an oil broker network working for the Quds Force (IRGC-QF).
“The IRGC-QF is using revenues from its Iranian petroleum sales to fund its malign activities at the expense of the Iranian people,” said Director of the Office of Foreign Assets Control Andrea M. Gacki. “These sales rely on key foreign intermediaries to obscure the IRGC-QF’s involvement, and Treasury will continue to disrupt and expose anyone supporting these efforts.”
OFAC’s sanctioned a foreign broker, Mahmood Rashid Amur Al-Habsi, who has partnered with senior IRGC-QF officials and used several companies to facilitate shipments of sanctioned Iranian oil to foreign customers, including buyers in East Asia.
Al-Habsi used his Oman-based company, Nimr International LLC, to facilitate the sale and shipment of Iranian oil in support of the IRGC-QF. Al Habsi also used Oman-based Orbit Petrochemicals Trading LLC to facilitate Iranian oil deals that obscure the IRGC-QF’s involvement. Both companies and Al-Habsi were sanctioned.
Also sanctioned was Bravery Maritime Corporation, a Liberian-registered company, controlled, directly or indirectly, by Al Habsi, as was the Liberian-flagged crude oil tanker Oman Pride, owned by this company, which has been used to transport Iranian oil.
Another link in this network, the Romania-based Nimr International SRL was also sanctioned for controlled, directly or indirectly, by Al Habsi.
June 10, 2021: Sanctions of Network Financing Yemen Houthi and Quds Force
On June 10, 2021, OFAC sanctioned members of a large smuggling network that helps fund Iran’s Islamic Revolutionary Guard Corps-Quds Force (IRGC-QF) and the Houthis in Yemen. Led by Iran-based Houthi financier Sa’id al-Jamal, this network generates tens of millions of dollars in revenue from the sale of commodities, like Iranian petroleum, a significant portion of which is then directed through a complex network of intermediaries and exchange houses in multiple countries to the Houthis in Yemen.
“This network’s financial support enables the Houthis’ deplorable attacks threatening civilian and critical infrastructure in Yemen and Saudi Arabia. These attacks undermine efforts to bring the conflict to an end and, most tragically, starve tens of millions of innocent civilians,” said Director of the Office of Foreign Assets Control Andrea M. Gacki. “Ending the suffering of millions of Yemenis is of paramount concern to the United States, and we will continue to hold accountable those responsible for widespread misery and deny them access to the global financial system.”
According to OFAC, Sa’id al-Jamal, an Iran-based Houthi financial supporter, directs a network of front companies and vessels that smuggle Iranian fuel, petroleum products, and other commodities to customers throughout the Middle East, Africa, and Asia. A significant portion of the revenue generated from these sales is directed through a complex international network of intermediaries and exchange houses to the Houthis in Yemen. This revenue helps fund the destabilizing regional activities of the Houthis, IRGC-QF, and others, including Hizballah.
Sa’id al-Jamal’s network has generated tens of millions of dollars in revenue through the sale of Iranian commodities to those willing to evade sanctions. Sa’id al-Jamal also maintains connections to Lebanese Hezbollah and has worked with the group to send millions of dollars to support the Houthis.
Lifting of Sanctions on Certain Individuals and Entities by President Joe Biden’s Administration
Since the start of Joe Biden’s presidency, several individuals and entities that had been sanctioned have been removed from the US sanctions list. The US government has announced that this action has nothing to do with the return to the nuclear deal (JCPOA) and has been an action based on the reevaluation of those individuals and entities.
December 12, 2022: One Iranian National Removed from the Sanctions List
OFAC, removed Iranian national Amir Hossein Bahreini, CEO of Arya Sasol Polymer. He had been added to the list on October 29, 2020, following an executive order by President Donald Trump in 2018 that reimposed nuclear sanctions on Iran.
Individuals and entities are removed from the sanctions list when the US government decides that either there has been a mistake or the situation has changed and it is no longer necessary to keep that individual or entity on the list.
September 23, 2022: General License to Increase Support for Internet Freedom in Iran
On September 23, 2022, following the outbreak of nationwide protests following the death of Mahsa Amini while in the custody of Morality Police, the American government issued a general license “to increase support for internet freedom in Iran by bringing US sanctions guidance in line with the changes in modern technology.”
This General License D-2 was an update to a previous general license and was issued after an Iranian citizen asked Elon Musk, the head of (among other companies) the Starlink satellite internet satellite business, to get a permit from the American government allowing people in Iran to use the services of this satellite network.
“While Iran’s government is cutting off its people’s access to the global internet, the United States is taking action to support the free flow of information and access to fact-based information to the Iranian people. The updated guidance will authorize technology companies to offer the Iranian people more options of secure, outside platforms and services,” announced the US Treasury.
“As courageous Iranians take to the streets to protest the death of Mahsa Amini, the United States is redoubling its support for the free flow of information to the Iranian people,” said Deputy Secretary of the Treasury Wally Adeyemo. “Today, Treasury is announcing the expansion of Iran General License D-2, which will expand the range of internet services available to Iranians. With these changes, we are helping the Iranian people be better equipped to counter the government’s efforts to surveil and censor them.
“This expanded general license would allow technology companies to provide more digital services to people in Iran, including social media platforms, collaboration platforms, video conferencing, as well as cloud-based services in support of such services. It also provides “additional authorization for the services that support the communication tools to assist ordinary Iranians in resisting repressive internet censorship and surveillance tools deployed by the Iranian regime,” Adeyemo said.
This action by the US Treasury was first criticized by Nasser Kanaani, spokesman for the Islamic Republic’s Foreign Ministry, and by the Supreme Leader Ali Khamenei, who said that reducing the sanctions on access to the internet was yet another proof that the United States was an “enemy”.
February 4, 2022: Waiving Sanctions on Third Country’s Participation in Iran’s Civil Nuclear Program
On February 4, 2022, US President Joe Biden’s administration waived certain sanctions on Iran’s civil nuclear programs. This waiver, issued 19 months after these sanctions were imposed by Donald Trump’s administration, allowed third countries, not the United States, to cooperate on certain non-proliferation activities necessary to return to the international nuclear agreement.
A senior State Department official denied that the step was a concession to Iran and instead characterized it as a “return to the status quo.”
These exemptions did not remove sanctions on Iran’s nuclear activities that have military dimensions but only allows third countries to engage in non-proliferation activities, such as removing dual-purpose material such as heavy water from Iran, to effectively make it harder for Iranian nuclear sites to be used for weapons development.
Among other things, these activities include a redesign of Iran's Arak heavy-water reactor, the preparation and modification of its Fordow facility for stable isotope production, and operations, training and services related to its Bushehr nuclear power plant.
October 8, 2021: Removal of Sanctions on Mammut Industrial Group and Its Subsidiaries
On October 8, 2021, in a rare action, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed sanctions on the Iranian Mammut Industrial Group and its subsidiaries, including Mammut Diesel Company.
Mammut Industrial Group and Mammut Diesel had been sanctioned in September 2020, during the last months of Donald Trump’s presidency, for contributing to Iran’s missile program by producing and supplying dual-use goods. At that time, the US government had announced that Mammut Industries had supported the production of ballistic missile equipment for Iran’s Aerospace Industries Organization (AIO) and, specifically, Shahid Hemmat Industrial Group, Iran’s primary developer of liquid propelled missiles.
OFAC announced that removing Mammut Industrial Group from the sanctions list does not mean the US had changed its policy regarding the Islamic Republic and the removal had nothing to do with negotiations for reviving the nuclear deal (JCPOA).
July 2, 2021: Removing 3 Individuals Connected with Mammut Industrial Group from the Sanctions List
On July 2, 2021, OFAC removed three individuals named Behzad Daniel Ferdows, Mehrzad Manuel Ferdows and Mohammed Reza Dezfulian from its sanctions list and said that this action was not related to negotiations for reviving the nuclear deal (JCPOA).
These three had been sanctioned in September 2020 in along with Mammut Industrial Group and its subsidiaries contributing to Iran’s missile program.
June 10, 2021: Removal of Sanctions on 3 Islamic Republic’s Oil Industry Executives
On June 10, 2021, in an unexpected development, the administration of President Biden removed three Islamic Republic’s oil executives from its sanctions list: Ahmad Ghalebani, former Managing Director of National Iranian Oil Company, Farzad Bazargan, former Managing Director of Hong Kong Intertrade Company and Mohammad Moini, a British-Iranian dual national and former commercial director of Naftiran Intertrade Company Sarl.
Ahmad Ghalebani had been sanctioned for the first time eight years ago.
The reason given by the US Treasury for these removals was the change in the situation of these individuals.
June 10, 2021: Removal of Sanctions on 2 Chinese Shipping Companies
On June 10, 2021, OFAC removed two shipping companies, Hong Kong-based Sea Charming Shipping Company Limited and Shanghai-based Shanghai Aoxing International Ship Management Company, from its sanctions list.
These two companies had been sanctioned in March 2020, near the end of Donald Trump’s presidency for carrying sanctioned Iranian petroleum and petrochemicals.
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