On February 3, in response to Iran’s latest ballistic missile test, which occurred on January 29, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned multiple entities and individuals involved in procuring technology and/or materials to support Iran’s ballistic missile program as well as supporting the Islamic Revolutionary Guard Corps-Quds Force (IRGC-QF).

Specifically, OFAC designated 13 individuals and 12 entities under several non-nuclear authorities including sanctions targeting global terrorism (designated with the tag [SDGT]) and the proliferation of weapons of mass destruction (designated with the tag [NPWMD]). According to OFAC, the designations were intended to disrupt four separate networks: (1) the Abdollah Asgharzadeh Network, including entities in both Iran and China; (2) the Gulf-based Rostamian Network, including entities in Iran and the United Arab Emirates; (3) an Iran-based network working with Navid Composite and Mabrooka Trading (both previously identified as Specially Designated Nationals (SDNs)); and (4) a Lebanese-based network supporting the IRGC-QF.

While these sanctions represent the first additions to the SDN list under President Trump and come on the heels of a sharp increase in confrontational rhetoric from both the U.S. and Iran, they do not represent a substantial change in U.S. policy and were likely being prepared for months; indeed, President Obama followed a similar pattern after taking office, designating Iran-based individuals and entities under the [SDGT] and [NPWMD] programs within six weeks after first taking office in 2009.

Because the designations were all issued under non-nuclear authorities, they also do not represent a violation of the U.S.’s commitments under the Joint Comprehensive Plan of Action (JCPOA). At most, the designations demonstrate an increased willingness by the new Administration to exercise its enforcement authorities after criticizing the Obama Administration for under-utilizing them.

For more information, contact: Jeff Snyder, Carlton Greene, Cari Stinebower, Chris Monahan, Dj Wolff, Charles De Jager

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice…

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations. He is experienced in providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws that can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.