In June, 2019, The Department of Treasury Office of Foreign Assets Control (OFAC) designated eight officials in the Islamic Revolutionary Guard Corps (IRGC) for malign activities both in and around Iran. President Trump issued an executive order named Imposing Sanctions with Respect to Iran. This executive order provides executive authority to designate anyone working for or acting on behalf of the Supreme Leader’s Office.

Background of the New Sanctions

A US drone was shot down in the Strait of Hormuz near the Persian Gulf, and the United States saw this as an act of aggression and claimed that the drone was in international airspace. Meanwhile, Iran claimed that the drone was in Iranian territory accompanied by a US manned aircraft, which was not shot down. As a result, the US considered plans for military action against Iran, likely military and nuclear-related sites. The president decided to withdraw the military orders prior to their occurrence and stated that harsh sanctions would be imposed on Iran and its leadership.

There is an ongoing discussion about further negotiations between the United States and Iran with regards to the US withdrawal from the JCPOA. Iran wants the United States to come back into the JCPOA and remove sanctions, and Iranian leadership has indicated that it is not willing to negotiate with the United States in these circumstances. French President Emmanuel Macron stated that he is going to attempt to convince President Trump that the removal of certain sanctions may help bring Iran to the negotiating table.

Potential Impact on US Persons and Entities

These sanctions will put on notice any individuals or entities that conduct business with anyone involved with the Supreme Leader and his office. Due to the ever-changing landscape of US sanctions, it is important for anyone conducting business overseas to ensure they are compliant and up-to-date with any required licenses. For help reviewing your transactions or your sanctions compliance program, reach out to a dedicated OFAC attorney.