January 13, 2021

OFAC targets organizations under the direct supervision of Iran’s supreme leader

The Office of Foreign Assets Control of the US Department of the Treasury has designated two Iranian organizations and their subsidiaries and leaders pursuant to Executive Order 13876, for being owned or controlled by the Supreme Leader of Iran, or for being a member of the board of directors or a senior executive of an organization that meets the definition of pertaining to the government of Iran, as set forth in Executive Order 13599.

The designated organizations, Execution of Imam Khomeini’s Order (EIKO) and Astan Quds Razavi (AQR), are bonyads, quasi-official organizations controlled by clerics or former government officials.  According to OFAC, these organizations command assets worth billions of dollars while receiving government benefits such as tax exemptions.  With their subsidiaries and affiliated companies, EIKO and AQR operate in the energy, telecommunications, financial, construction and agriculture sectors of the Iranian economy; both, according to OFAC, are under the direct supervision of the Iran’s Supreme Leader.

Pursuant to these designations, US property of the designated persons is blocked, and OFAC regulations generally prohibit dealings by US persons involving the property or interests in property of blocked and designated persons.  Furthermore, those who engage in certain transactions with designated persons may themselves be exposed to sanctions, and financial institutions that knowingly facilitate significant transactions on behalf of designated persons may be subject to US correspondent account or payable-through account sanctions.

US Dept of the Treasury press release