On May 1, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the designation of Amir Dianat, a senior official in Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), pursuant to Executive Order 13224, as amended by EO 13886. According to the press release, the dual Iranian and Iraqi national was designated for allegations that he assisted the IRGC-QF with generating revenue and trafficking weapons abroad. Pursuant to Executie Order 13224, OFAC also designated Taif Mining Services LLC, a company owned and controlled by Dianat that, in 2019, was used purchase an oil tanker for the IRGC-QF. The US Department of Justice for the District of Columbia concurrently filed charges against Dianat and a business associate for sanctions and money laundering violations, and also filed a related $12 million civil forfeiture action for funds allegedly used in these crimes and as assets of a foreign terrorist organization.
As a result of these sanctions, US property of the designated person and entity is blocked, and all transactions and dealings with US persons are generally prohibited. Furthermore, any person who transacts with the designated person or entity may themselves be exposed to sanctions, and foreign financial institutions that knowingly facilitate significant transactions on their behalf could be subject to US correspondent account or payable-through account sanctions.