Today, the US State and Treasury Departments imposed sanctions against over 30 parties linked to Iran, including five Iranian banks, an Iranian-owned Russian bank, two airlines, two logistics companies, six vessels, and several shipping and energy companies. The designations have been made under a variety of different sanctions authorities, including sanctions targeting Iran, global terrorism and WMD proliferation. Some parties were designated for providing material support to other designated parties. These actions demonstrate the US government’s commitment to enforcing sanctions against Iran during the course of ongoing negotiations between Iran and the P5+1 over Iran’s nuclear program.
Over 30 entities, individuals, and vessels were designated and “blocked” as Specially Designated Nationals (“SDNs”) by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) or the State Department. A list of the SDN designations is available here. U.S. Persons are prohibited from engaging in any transactions with SDNs, and all property or interests in property in which an SDN has an interest must be blocked.
The new SDNs include the following:
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Asia Bank (a.k.a Chemeximbank): An Iranian-owned bank located in Russia designated under Executive Order 13662 for providing material support to designated Iranian banks, including by facilitating US dollar bank note transactions for Iranian government officials and pursuing correspondent relationships on behalf of designated banks.
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Khavarmianeh Bank, Ghavamin Bank, Gharzolhasaneh Resalat Bank, Kish International Bank, and Kafolatbank: Banks designated under Executive Order 13599 for being Iranian financial institutions; although all Iranian financial institutions are already considered blocked, these banks are now identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).
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Caspian Air and Meraj Air: Iranian airlines designated under Executive Order 13224 for activities in support of terrorism, including supplying weapons to Syria; the travel exemption that is available under most OFAC sanctions programs is not available for transactions with these airlines.
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Pioneer Logistics and Asian Aviation Logistics: A Turkey-based logistics company and Thailand-based logistics company designated under Executive Order 13224 for acting for or on behalf of the designated airline, Mahan Air; the travel exemption is not available for transactions with these entities.
In addition, the State Department separately imposed so-called secondary sanctions against two entities based in the UAE and Italy respectively for engaging in targeted activities involving Iran. A list of the State Department designations is available here. These entities have also been added to the SDN List. The entities are expected to be subject to additional penalties, as set forth in the Iran Sanctions Act of 1996 (“ISA”), but it is not yet clear which additional ISA penalties the US government will apply (e.g., restrictions on restrictions on access to US correspondent banking systems, a ban on US government contracting, etc.).
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Goldentex FZE: A UAE-based company sanctioned under the Iran Freedom and Counter-Proliferation Act of 2012 for providing support to Iran’s shipping sector.
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Dettin SpA: An Italy-based company sanctioned under the ISA, as amended by the Iran Threat Reduction and Syria Human Rights Act of 2012, for providing goods or support to Iran’s petrochemical industry in excess of $250,000.
Companies should exercise caution when engaging in transactions in which the above parties are involved. Many of the designations have been made under the general Iran sanctions pursuant to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560, which apply not only to U.S. Persons but also to non-US companies owned-or-controlled by U.S. Persons.
The Treasury Department press release announcing this action is available here, and the State Department press release is available here.
