In its continuing effort to tighten economic sanctions on Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned five United Arab Emirates (UAE)-based companies that facilitate the Iranian regime’s petroleum and petrochemical sales. According to OFAC, these companies in 2019 “collectively purchased hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (NIOC),” a major source of revenue to fund and support the Islamic Revolutionary Guard Corps-Qods Force’s (IRGC-QF). OFAC designated and placed on the Specially Designated Nationals (SDN) List (1) Petro Grand FZE, (2) Alphabet International DMCC, (3) Swissol Trade DMCC, (4) Alam Althrwa General Trading LLC, and (5) Alwaneo LLC Co. Treasury Secretary Steven Mnuchin stated, “The Trump Administration will continue to target and isolate those who support the Iranian regime and remains committed to facilitating humanitarian trade and assistance in support of the Iranian people.”

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.

Similarly, on March 16, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) added Iran Air and five Iranian nationals to the Entity List. Iran Air was added due to its transportation of military-related equipment on behalf of Iran’s Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense and Armed Forces Logistics (MODAFL). Aref Bali Lashak, Kamran Daneshjou, Mehdi Teranchi, Ali Mehdipour Omrani, and Sayyed Mohammad Mehdi Hadavi have been added due to their involvement in nuclear-related activities that are contrary to the national security and/or foreign policy interests of the United States. As a result, BIS has imposed a license requirement for all export transactions with these entities. For Iran Air, the licensing policy will be case-by-case review for licenses for the safety of civil aviation and the safe operation of aircraft; for the Iranian nationals, BIS has imposed a presumption of denial for any license applications.