Recent update to Iran sanctions - Sanctioned entities/persons added

On 03 February 2017, the Office of Foreign Assets Control (OFAC) of the USA Department of the Treasury, which administers and enforces economic and trade sanctions based on USA foreign policy and national security goals, updated its list of Specially Designated Nationals (SDNs) and Blocked Persons, adding more than 20 entities/individuals (located in several jurisdictions, including Iran, Lebanon and China).

OFAC have stated that these updates are in connection with, amongst other things, sanctions against Iran’s ballistic missile programme, and have stated that the updates are consistent with the existing commitments under the Joint Comprehensive Plan of Action (the JCPOA - commonly referred to as the “Iran nuclear agreement”). The action followed the announcement from USA President Donald Trump’s administration on 01 February 2017 that Iran was “on notice” following Iran’s recent ballistic missile exercises.

OFAC have stated that the entities and individuals identified were involved in exporting dual-use technology (technology which may be utilised for purposes of military, ballistic or nuclear-enrichment) to Iran. As such, companies looking to export equipment (including those typically used in the energy industry) to Iran should ensure that:

• enhanced due diligence has been conducted on any Iranian counterparties, and
• check whether such equipment is in fact a "dual-use" item and obtain export-control approvals from the relevant authorities should this be the case, as part of ensuring compliance with the relevant sanctions.

The original OFAC Press Release can be accessed here.