On January 10, 2020, President Donald Trump issued “Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran,” implementing further sanctions on Iran and blocking the assets and property of additional senior Iranian government officials. The executive order authorizes economic sanctions on entities operating in the construction, mining, manufacturing or textiles sectors of the Iranian economy. The sanctions also target any persons or entities that knowingly engage in a significant transaction for the sale, supply or transfer to or from Iran of significant goods or services used in connection with Iranian entities designated by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) in these sectors of the Iranian economy, as well as any persons or entities who may materially assist, sponsor or provide financial, material or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to OFAC. The executive order authorizes secondary sanctions on foreign financial institutions that may engage in transactions with persons or entities designated pursuant to the executive order.
In a message to Congress, Trump stated that the executive order “takes steps to deny Iran revenue, including revenue derived from the export of products from key sectors of Iran’s economy, that may be used to fund and support its nuclear program, missile development, terrorism and terrorist proxy networks, and malign regional influence.” Pursuant to the executive order, OFAC has designated and placed on the Specially Designated Nationals (SDN) List 17 Iranian metals producers and mining companies; a network of three China- and Seychelles-based entities; and a vessel involved in the purchase, sale and transfer of Iranian metals products, as well as in the provision of critical metals production components to Iranian metal producers.
In addition to these economic sanctions on sectors of the Iranian economy, Secretary of State Mike Pompeo and Secretary of the Treasury Steven Mnuchin announced in a press briefing that the United States was “taking action against eight senior Iranian officials who advanced the regime’s destabilizing activity and were involved in [the January 7, 2020] ballistic missile strike” on air bases in Iraq. These officials have been placed on OFAC’s SDN List: (1) Ali Shamkhani, the Secretary of Iran’s Supreme National Security Council; (2) Mohammad Reza Ashtiani, the Deputy Chief of Staff of Iranian armed forces; (3) Gholamreza Soleimani, the head of the Basij militia of the Islamic Revolutionary Guards Corps (IRGC); (4) Mohsen Reza’i, a member of Iran’s Expediency Council; (5) Mohammad Reza Naqdi, the Deputy Coordinator of the IRGC; (6) Ali Abdollahi, a senior Iranian military appointee of the Supreme Leader and former Deputy Commander of Iran’s Law Enforcement Forces; (7) Ali Asghar Hejazi, a senior official within the Supreme Leader’s Office in charge of security; and (8) Mohsen Qomi, a Deputy Advisor for International Affairs in the Supreme Leader’s Office and an advisor to the Supreme Leader on International Communications.
The full and detailed list of the Iran-related Designations and Updates is available on Treasury’s website.
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.