The USA has today imposed sanctions on companies and individuals that are “engaged in proscribed activities” and “providing support to illicit Iranian nuclear activities”. The State Department press release states that these actions “underscore U.S. resolve to enforce sanctions as the P5+1 and Iran work toward a comprehensive solution to address the international community’s concerns over Iran’s nuclear program”.
The new US sanctions take the following form:
(1) Sanctions on 4 companies pursuant to Executive Order (E.O.) 13382 for engaging in or attempting to engage in “activities that have materially contributed to, or posed a risk of materially contributing to, the proliferation of WMD or their means of delivery”. The Department of State’s designations comprise Iran-based entities engaged in efforts to support the development of nuclear weapons, or elements of Iran’s program that could be used to produce nuclear weapons. The 4 companies are the Organization of Defensive Innovation and Research, the Nuclear Science and Technology Research Institute, Jahan Tech Rooyan Pars, and Mandegar Baspar Kimiya Company. Under the same Executive Order, the US Treasury Department has also designated Mohammad Javad Imanirad and Arman Imanirad for acting for or on behalf of designated Iranian company, Aluminat, and Nefertiti Shipping for its ties to the Islamic Republic of Iran Shipping Lines (IRISL).
(2) Sanctions pursuant to the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) on Goldentex FZE, a UAE-based company said to be “involved in providing support to Iran’s shipping sector”. IFCA mandates, among other things, the imposition of sanctions on individuals and companies determined to have knowingly transferred to or from Iran significant goods or services used in connection with the energy or shipping sector of Iran, including the National Iranian Oil Company or the National Iranian Tanker Company (NITC).
(3) Sanctions on Italy-based Dettin SpA pursuant to the Iran Sanctions Act of 1996 (ISA), as amended by the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA). Dettin SpA is said to have been “knowingly providing Iran’s petrochemical industry with goods and support whose value exceeded $250,000”. The press release states that “although the JPOA authorizes Iran to export petrochemicals, providing goods, services, and support for the maintenance or expansion of Iran’s domestic production of petrochemicals is not within the scope of sanctions relief under the JPOA and, therefore, remains sanctionable.”
The new US Treasury Department sanctions are, in addition, as follows:
(1) Treasury designated two entities and three individuals tied to Iran’s energy industry pursuant to E.O. 13645. They are Faylaca Petroleum, Abdelhak Kaddouri, Muzzafer Polat, and Seyedeh Hanieh Seyed Nasser Mohammad Seyyedi. It also identified 6 vessels pursuant to this authority, connected with Lissome Marine Services LLC.
(2) Treasury designated one entity (Asia Bank) pursuant to E.O. 13622 for its provision of material support to the Central Bank of Iran in connection with the purchase or acquisition of U.S. dollar bank notes by the Government of Iran.
(3) Treasury identified 5 Iranian banks that are subject to sanctions under E.O. 13599, which blocks the property and interests in property of the Government of Iran and Iranian financial institutions. They are
Khavarmianeh Bank, Ghavamin Bank, Gharzolhasaneh Resalat Bank, Kish International Bank, and Kafolatbank.
(4) Treasury designated 4 entities and one individual pursuant to E.O. 13224 in connection with Iran’s support for terrorism. They are Meraj Air, Caspian Air, Sayyed Jabar Hosseini, Pioneer Logistics and Asian Aviation Logistics.