On May 20, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the designation of Iran’s Interior Minister along with seven senior officials of Iran’s Law Enforcement Forces (LEF) and a commander of Iran’s Islamic Revolutionary Guard Corps (IRGC). These designations are made pursuant to Executive Order 13553, that imposes sanctions on persons who commit human rights abuses by the Government of Iran. OFAC also designated the Bonyad Taavon NAJA, also known as the LEF Cooperative Foundation, and its managing director, pursuant to E.O. 13553, for being owned or controlled by the LEF.
The LEF is responsible for operating detention centers where government protestors have been physically and psychologically abused, and was recently implicated in the torture and drowning of Afghan nationals who attempted to cross Iran’s border. The LEF and IRGC were both designated back in 2011, pursuant to E.O. 13553, for being complicit in serious human right abuses. The IRGC has also been designated under counterterrorism and counter proliferation authorities, and the LEF has also been designated for its support of the Bashar Al-Assad regime in Syria.
As a result of these sanctions, all US property for the designated persons is blocked, and all transactions and dealings with US persons are generally prohibited. Furthermore, any person who transacts with a designated person 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.