On 29 August, the U.S. Treasury and State Departments added a number of individuals and entities to the SDN List under Iran-related sanctions programs, including companies based in the United Arab Emirates and Italy that were subjected to so-called “secondary sanctions” programs based on their dealings with blocked Iranian parties. In an announcement accompanying the new designations, the State Department emphasised that it was continuing to enforce existing sanctions while negotiations continue between Iran and the P5+1 nations (also known as the E3+3) over Iran’s nuclear program. Iran’s Oil Minister Bijan Zanganeh was quoted in a Reuters article as saying that Iran would continue its efforts to circumvent sanctions imposed by the West.
The parties added to the SDN List are blocked, meaning that US persons cannot engage in any transactions with them, and that their assets in the US or in the possession or control of a US person must be frozen. This is in addition to the general prohibitions under the Iranian Transactions and Sanctions Regulations on trade with Iran by US persons and entities owned or controlled by them.
The first set of new SDN designations was based on EO 13382, which targets proliferators of weapons of mass destruction (“WMD”) and their supporters. Under that authority, the Treasury Department newly designated four individuals and two entities and listed new aliases for a previously sanctioned key Iranian missile proliferator. Mohammad Javad Imanirad and Arman Imanirad were designated for acting on behalf of a sanctioned entity, Aluminat, which, according to the Treasury Department, has provided centrifuge components to support Iran’s nuclear program. Nefertiti Shipping was designated for being the Egyptian agent for Islamic Republic of Iran Shipping Lines (“IRISL”). Ali Gholami and Marzieh Bozorg, the Managing Director and Commercial Director, respectively, of Sazeh Morakab, as well as Sazeh Morakab itself, were designated for procuring
materials on behalf of various sanctioned Iranian defence industry companies, including Shahid Hemat Industrial Group, which the Treasury Department also identified as operating under two aliases, Sahand Aluminum Parts Industrial Company (“SAPICO”) and Ardalan Machineries Company (“ARMACO”).
Simultaneously, the US State Department announced the listing of four additional entities for WMD activities pursuant to EO 13382. According to the State Department, the Organisation of Defensive Innovation and Research, based in Tehran, was established by Mohsen Fakhrizadeh, who is sanctioned by the United Nations, and was designated by the State Department for alleged involvement in Iran’s WMD activities. Iran’s Nuclear Science and Technology Research Institute works with Iranian entities involved in the operation and development of Iran’s heavy water research reactor at Arak, which is capable of producing nuclear material capable of use in nuclear weapons. Jahan Tech Rooyan Pars (Jahan Tech) and Mandegar Baspar Kimiya Company (Mandegar Baspar), both based in Iran, were designated by the State Department for alleged involvement in the procurement of proliferation-sensitive material for proscribed elements of Iran’s nuclear program.
The second set of designations was directed against Iran’s energy industry. Pursuant to EO 13645, Treasury designated Faylaca Petroleum and related individuals, stating that the company, together with the already-designated Sima General Trading, markets Iranian crude oil and petroleum products, obscures the origin of Iranian gas condensate and makes payments on behalf of the Iranian government’s National Iranian Oil Company (“NIOC”). Additionally, the individuals Abdelhak Kaddouri, Muzzafer Polat and Seyedeh Hanieh Seyed Nasser Mohammad Seyyedi were also designated. Mr. Kaddouri is the financial chief of the Naftiran Intertrade Company Sarl (“NICO”), a subsidiary of NIOC, and associated with Swiss Management Services Sarl, both of which are sanctioned entities. Mr. Polat is the founder, director general and manager of Petrol Royale FZE, and designated for alleged involvement with Faylaca Petroleum for marketing Iranian crude oil and petroleum products as well as obscuring the origin of Iranian gas condensate. Ms. Seyyedi is Faylaca Petroleum’s Managing Director. Finally, the Treasury Department also designated Lissome Marine Services LLC for using its vessels to support the National Iranian Tanker Company (“NITC”).
Another set of designations targeted Iranian banks and Iranian-owned foreign banks. Asia Bank, formerly Chemeximbank, an Iranian-owned bank based in Moscow, Russia, was designated under EO 13662 for coordinating the delivery of U.S. dollar bank notes to the Iranian government as well as providing support to two designated Iranian banks, Export Development Bank of Iran and Bank Tejarat, by assisting in setting up correspondent accounts. The Treasury Department also identified as Iranian financial institutions pursuant to EO 13559 four additional banks in Iran as well as Kafolatbank, an Iranian-owned bank based in Tajikistan. This subjects these banks to blocking sanctions.
The Treasury Department also expanded Counter-Terrorism-Related Designations under 13224. Meraj Air, Caspian Air and Pouya Air were designated for providing support to Iran’s Islamic Revolutionary Guard Corps (“IRGC”), including the transportation of weapons to Syria, and Sayyed Jabar Hosseini was also designated for allegedly coordinating shipments on behalf of the IRGC to Sudan and Syria. Additionally, Pioneer Logistics, based in Turkey, and Asian Aviation Logistics, based in Thailand, were designated for supporting Mahan Air, which was itself designated in 2011 for providing support to the IRGC.
In addition, the US imposed sanctions on two non-Iranian companies under the so-called “secondary sanctions” laws. In particular, the State Department announced sanctions on Goldentex FZE, a UAE-based entity, pursuant to authority granted under the Iran Freedom and Counter- Proliferation Act of 2012, for providing support to Iran’s shipping sector. Dettin SpA, an Italy-based entity, was also sanctioned for knowingly providing Iran’s petrochemical with goods and support exceeding $250,000 in value, which actions were made sanctionable by the Iran Threat Reduction and Syria Human Rights Act of 2012. While these laws allow the State Department to choose from a menu of possible sanctions, it appears that Goldentex and Dettin were subject to the most severe available sanction, that is, being placed on the SDN list and therefore blocked.