OFAC sanctions Iran’s Central Bank Governor and Iraqi Bank

US Treasury Building.jpgYesterday, OFAC designated an Iraq-based bank (Al-Bilad Islamic Bank) and 4 people as Specially Designated Global Terrorists, pursuant to Executive Order 13224, for “mov[ing] millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hizballah”. All are now subject to asset freezing measures and secondary sanctions under the Iranian or Hizballah Financial Sanctions Regulations (prohibitions or strict conditions on the opening or maintaining in the US of a correspondent account or a payable-through account by a foreign financial institution). OFAC Notice and Treasury press release.

The 4 designated individuals are Valiollah Seif (Iran’s Central Bank Governor), Ali Tarzali (assistant director of the International Department at the Central Bank of Iran), Aras Habib Kareem (Chairman and Chief Executive of Al-Bilad Islamic Bank), and Muhammad Qasir (Hizballah official).

The designations of Mr Seif and Mr Tarzali do not extend to the Central Bank of Iran.  However, due to President Trump’s decision to cease US participation in the JCPOA, as of 7 August 2018, the US will re-impose sanctions that extend to certain transactions with the Central Bank of Iran, including sanctions on the purchase or acquisition of US dollar banknotes by the Government of Iran. Furthermore, on 5 November 2018, additional sanctions will be re-imposed on persons knowingly engaging in certain significant transactions with the Central Bank of Iran.

Last week, OFAC sanctioned an IRGC-QF-associated currency exchange network procuring millions of dollars through the UAE (previous blog).

This entry was posted in Iran, Iraq, Terrorist Sanctions, USA by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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