Yesterday, 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).