On the 40th anniversary of the Iranian takeover of the U.S. Embassy in Tehran and the hostage-taking of more than 50 U.S. diplomats and officials, the United States announced November 4, 2019, a further tightening of sanctions on Iran. In its statement supporting these sanctions, the White House explained, “The Iranian regime continues to target innocent civilians for use as pawns in its failed foreign relations. Until Iran changes this and its other hostile behavior, we will continue to impose crippling sanctions.”
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that Iran’s Armed Forces General Staff (AFGS) and nine individuals have been blocked and added to OFAC’s Specially Designated Nationals (SDN) List. The AFGS, the most senior military body in Iran, implements policy and monitors and coordinates activities within the armed forces. OFAC’s additions of individuals to the SDN List encompasses unelected officials who were appointed and are close to Iran’s Supreme Leader Ali Khamenei, including the head of Iran’s Judiciary, Khamenei’s chief of staff, Khamenei’s second son, as well as several senior advisers and military aides. Secretary of the Treasury Stephen Mnuchin stated, “These individuals are linked to a wide range of malign behaviors by the regime, including bombings of the U.S. Marine Barracks in Beirut in 1983 and the Argentine Israelite Mutual Association in 1994, as well as torture, extrajudicial killings, and repression of civilians. This action further constricts the Supreme Leader’s ability to execute his agenda of terror and oppression.”
As a result of this action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Because U.S. persons are generally prohibited from dealing with entities on the SDN List, persons who engage in certain transactions with these designated persons may themselves be exposed to designation. OFAC has indicated that any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for these persons could be subject to U.S. correspondent account sanctions or payable-through account sanctions.