The US Department of the Treasury’s Office of Foreign Assets Control recently designated three Deputy Directors of the Atomic Energy Organization of Iran (AEOI) and a number of the organization’s subsidiaries pursuant to Executive Order 13382, which targets those who proliferate weapons of mass destruction. Several senior officials who work in Iran’s missile program and multiple companies that provide equipment for Iran’s ballistic missile production were also designated. These actions were taken on September 21, 2020, in support of the re-imposition of the UN sanctions on Iran that were lifted under UN Security Council Resolution 2231.
As a result of these designations, all interests in US property are blocked, and transactions and dealings with the designated persons are generally prohibited. In addition, persons who engage in transactions with a designated person or entity may themselves be exposed to sanctions, and any foreign financial institution that knowingly conducts transactions on behalf of a designated person or entity could be subject to US sanctions.