TREASURY DEPARTMENT CONTINUES TO IMPLEMENT IRAN SANCTIONS
December 21, 2018
The U.S. Treasury Department stepped up its enforcement of Iranian sanctions violations as the Trump administration focuses on curtailing flows of sanctioned currency and technology to Iran. This month marked the expiration of a six-month transition period following the U.S. withdrawal from the Iran Nuclear Deal. On November 5, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on more than 700 individuals, entities, aircraft, and vessels as part of its return to a policy of maximum pressure against elements of the Iranian government. In the aviation sector, OFAC listed Iran Air and 67 of its aircraft as specially designated nationals (SDNs). OFAC also cautioned that “persons that engage in certain transactions with the entities designated and identified [pursuant to Executive Orders] may themselves be exposed to enforcement action, designation, or blocking sanctions.”
OFAC and the Department of Justice continue to vigorously pursue Iran-related sanctions and export control violations. For instance, on November 8, an Iranian citizen named Arash Sepehri pled guilty in federal court in Washington, D.C. for conspiracy to unlawfully export goods to Iran, to defraud the U.S., and money laundering. Sepehri and his co-conspirators used fake names and companies to ship Department of Commerce-controlled items, and as well as items controlled by the U.S. Munitions List, to Iran via intermediary countries. He will be sentenced early next year.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Alexander Matthews (amatthews@eckertseamans.com or 202-659-6633).
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