Almost immediately after the Trump administration’s announcement that Iran was in compliance with the terms of the Joint Comprehensive Plan of Action (JCPOA), the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the State Department designated an additional 18 Iranian entities and individuals for engaging in activities supporting Iran’s continued testing of ballistic missiles, as well as for engaging in activities supporting Iran’s military or Iran’s Islamic Revolutionary Guard Corps (IRGC).
OFAC has designated three networks supporting Iran’s military and/or the IRGC through the development of unmanned aerial vehicles and military equipment for the IRGC, the production and maintenance of fast attack boats for the IRGC-Navy, or the procurement of electronic components for entities that support Iran’s military. Additional persons and entities were added to OFAC’s Specially Designated Nationals List for Iran-based transnational criminal organization activities, including the theft of U.S. and western software programs which, at times, were sold to the Iranian government. A complete listing of OFAC designations is available on Treasury’s website.
The State Department designated two entities for engaging in activities that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery: the IRGC’s Aerospace Force Self Sufficiency Jihad Organization, which is involved in Iranian ballistic missile research and flight test launches, and the IRGC’s Research and Self Sufficiency Jehad Organization, which is responsible for the research and development of ballistic missiles.
The State Department stated that Iran continues to test and develop ballistic missiles in direct defiance of United Nations Security Council Resolution 2231, and referred to the JCPOA’s statement regarding the participants’ anticipation that “full implementation of this JCPOA will positively contribute to regional and international peace and security.” In announcing these new sanctions, however, State Department officials stated that “Iran’s other malign activities are serving to undercut whatever ‘positive contributions’ to regional and international peace and security were intended to emerge from the JCPOA.” In announcing these new sanctions, the Trump administration stated that it is continuing to conduct a full review of U.S. policy toward Iran and that the United States during this review will continue to aggressively counter Iran’s activities in the region.