On March 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against “25 individuals and entities, including a network of Iran, UAE, and Turkey-based front companies,” for allegedly transferring “over a billion dollars and euros” in funds to the Islamic Revolutionary Guard Corps (IRGC) and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). Among other things, the designated individuals and entities also procured vehicles worth millions of dollars for MODAFL, which was also sanctioned, along with Iran’s IRGC-controlled bank and currency exchange arm, for allegedly providing assistance and banking services to the IRGC-Qods Force. According to OFAC, the sanctions were issued pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations.” As a result, all property and interests in property belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from entering into transactions with them. In addition, OFAC noted that persons who engage in transactions with the designated individuals and entities may be exposed to sanctions themselves or subject to enforcement action. Moreover, OFAC warned foreign financial institutions that, unless an exemption applies, they may be subject to U.S. sanctions if they knowingly facilitate significant transactions for any of the designed individuals or entities.

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