The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has amended its Global Terrorism Sanctions Regulations (GTSR) in order to impose additional sanctions on Iran’s Islamic Revolutionary Guard Corps (IRGC) within the timeline required by the Countering America’s Adversaries Through Sanctions Act (CAATSA). Effective October 31, 2017, persons and entities that OFAC has designated as officials, agents, or affiliates of the IRGC remain subject to secondary blocking sanctions which continue to prohibit them from engaging in activity with US and non-US persons and, in addition, these amendments to the GTSR now impose new sanctions to prohibit the designated IRGC affiliates from receiving humanitarian donations and other forms of assistance. OFAC has provided a list of the IRGC affiliates subject to these amendments here.
In addition, the U.S. Department of State recently provided guidance required under Section 231(d) of CAATSA and has identified 37 entities and individuals as “persons that are part of, or operate for or on behalf of, the defense and intelligence sectors of the Government of the Russian Federation.” CAATSA will now require President Trump to impose additional sanctions against those entities and individuals on or before January 29, 2018. However, CAATSA does give the President some flexibility in choosing which specific sanctions to implement.