The Treasury Department’s Office of Foreign Assets Control has designated, pursuant to Executive Order 13876, the Armed Forces General Staff of Iran and nine persons who have acted on behalf of Iran’s Supreme Leader. The designations target appointees of the Supreme Leader, the Expediency Council, the Armed Forces General Staff, and the Judiciary, and include one of Ayatollah Khamenei’s sons. According to OFAC, the designated individuals have been implicated in the persecution of the Baha’I community in Iran, the execution of juveniles, and the bombings of the US Marine Corps compound in Beirut in 1983 and the Argentine Israelite Mutual Association in Buenos Aires in 1994.
Pursuant to these sanctions, all US property of the designated persons is blocked, and US persons are generally prohibited from dealing with such property. Persons who engage in certain transactions with designated persons may be subject to designation by OFAC, and any foreign financial institution that knowingly conducts or facilitates a significant transaction on behalf of a designated person could be subject to US correspondent account or payable-through sanctions.