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Today, Feb. 3, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned numerous new entities and individuals. These sanctioned parties are believed to have been involved in procuring technology and/or materials to support Iran’s ballistic missile program, or acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).

The action comes just two days after Iran launched a ballistic missile near Semnan, Iran. This latest missile launch is merely the latest in a series of missile tests Iran began shortly after the implementation of the Joint Comprehensive Plan of Action reached on July 14, 2015, by China, France, Germany, Russia, the United Kingdom, and the United States, the European Union, and Iran.

The Trump administration is plainly taking a hardline approach to violations of this U.N. resolution. Yesterday, Feb. 2, 2017, National Security Adviser Mike Flynn announced that the administration was “officially putting Iran on notice” that it would not accept ballistic missile tests or continued attacks by proxy forces in Yemen on U.S. and Middle Eastern ships. This morning, President Donald Trump issued a tweet, stating that Iran is "playing with fire," adding that he will not be "as kind" as former President Barack Obama had been. Although the overarching intent of the JCPOA nuclear agreement was to limit Iran’s development of nuclear weapons in exchange for sanctions relief, OFAC takes the position the imposition of new sanctions is “fully consistent” with the United States’ commitments under the Joint Comprehensive Plan of Action. Given the Trump administration’s avowed “commitment to enforcing sanctions on Iran with respect to its ballistic missile program and destabilizing activities in the region,” it seems that additional economic sanctions for Iran could be on the table in the future.

The individuals and entities subject to the new sanctions include:
  • Several networks and supporters of Iran’s ballistic missile procurement, including Abdollah Asgharzadeh, an Iranian procurement agent and eight individuals and entities in his Iran- and China-based network, MKS International, an Iranian procurement company and its Gulf-based network, as well as five individuals and entities that are part of an Iran-based procurement network connected to Mabrooka Trading. 
  • A key IRGC-QF-run support network alleged to be working with Hizballah, including IRGC-QF official Hasan Deghan Ebrahimi, his associates Muhammad Abd-al-Amir Farhat and Yahya al-Hajj, and several affiliated companies in Lebanon. 
  • Ali Sharifi, an individual providing procurement and other services on behalf of the IRGC-QF. 
  • The sanctions imposed were taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction and their means of delivery and supporters of such activity, and E.O. 13224, which targets terrorists and those providing support to terrorists or acts of terrorism. 
Businesses are advised to ensure that their economic sanctions screening programs are up-to-date and include these newly sanctioned individuals and entities. Companies are encouraged to contact Mary Edquist with any specific questions concerning the impact of these latest sanctions.
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