Today, the U.S. Treasury Department, Office of Foreign Assets Control (“OFAC”) imposed sanctions on an additional 13 individuals and 12 entities1 identified by the Treasury Department as “entities and individuals involved in procuring technology and/or materials to support Iran’s ballistic missile program, as well as for acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods Force.” As every individual and entity concerned was also made the subject of secondary sanctions, the crucial effect is that both U.S. and non-U.S. companies and individuals can be penalized and sanctioned for dealing with the designated parties.

White House Press Secretary Sean Spicer stated that the new designations were made, in part, as a response to a missile test Iran conducted January 29, 2017. The press secretary also hinted at future action, emphasizing that the Trump administration “will continue to respond with appropriate action” to “aggressively target Iran’s ballistic missile program and terrorism related activities.”

For immediate reference, the 13 individuals designated were:

  1. Al-Hajj, Yahya (A.K.A. Al-Haj, Yahya; A.K.A. Al-Haj, Yehia Issa Mohamad)
  2. Asgharzadeh, Abdollah
  3. Darian, Tenny (A.K.A. Shakhdarian, Tenny)
  4. Ebrahimi, Hasan Dehghan (A.K.A. Ibrahimi, Hasan Dahqan)
  5. Farhat, Muhammad 'Abd-Al-Amir (A.K.A. Farhat, Mohammad; A.K.A. Farhat, Mohammad Abdul Amir)
  6. Magham, Mohammad
  7. Rostamian, Kambiz
  8. Sharifi, Ali (A.K.A. Salehi, Ali)
  9. Xianhua, Qin (A.K.A. Qin, Jack; A.K.A. Xianhua, Jack)
  10. Yue, Richard (A.K.A. Yaodong, Yue)
  11. Zahedi, Mostafa (A.K.A. Khaze, Karim; A.K.A. Liu, Jhon; A.K.A. Omar, Asem; A.K.A. "Ibrahim, Mohammad"; A.K.A. "Ibrahim, Mohammed")
  12. Zargari, Ghodrat (A.K.A. Zargari, Ghodratollah)
  13. Zhou, Carol

The 12 Entities Designated Were:

  1. Cosailing Business Trading Company Limited
  2. East Star Company (A.K.A. Satereh Shargh Mobin Co.; A.K.A. Satereh Shargh Samin Co., Ltd.; A.K.A. Setareh Shargh Co.)
  3. Ervin Danesh Aryan Company (A.K.A. Ervin Danesh)
  4. Maher Trading And Construction Company (A.K.A. Maher Trading And Engineering; A.K.A. "Maher Company")
  5. Mirage For Engineering And Trading (A.K.A. "Mirage For Engineering")
  6. Mirage For Waste Management And Environmental Services Sarl
  7. Mks International Co. Ltd. (A.K.A. Mks International; A.K.A. Mks International Group)
  8. Ningbo New Century Import And Export Company, Ltd. (A.K.A. New Century Import And Export Co. Ltd)
  9. Ofog Sabze Darya Company
  10. Reem Pharmaceutical (A.K.A. Reem Pharmaceutical, Llc; A.K.A. Reem Pharmaceutical, S.A.R.L.; A.K.A. Reem Pharmaceutical, Sal)
  11. Royal Pearl General T.R.D. (A.K.A. Royal Pearl Chemical; A.K.A. Royal Pearls; A.K.A. Royal Pearls General Trading)
  12. Zist Tajhiz Pooyesh Company (A.K.A. Pooyesh Environmental Instruments; A.K.A. Ziest Tajhiez Pooyesh)