On September 3, 2021, the US Department of the Treasury’s Office of Foreign Assets Control designated four Iranian operatives for engaging in a campaign to silence critics of the Iranian government by participating in a failed attempt to kidnap a US journalist and human rights activist and several Iranian dissidents in the US, UK, Canada and the United Arab Emirates in an attempt to return the dissidents to Iran. Iran’s Ministry of Intelligence and Security (MOIS) is well-known for domestic repression and using its intelligence arm to return Iranians located abroad to Iran. The four Iranian operatives were designated pursuant to Executive Order 13553 for, directly or indirectly, acting on behalf of the MOIS. The MOIS was designated in 2012, pursuant to Executive Order 13224, for supporting terrorism, and pursuant to EO 13553, for committing serious human rights abuses against the people of Iran since 2009.
As a result of these sanctions, all US property belonging to designated individuals is blocked, and all transactions with US persons are generally prohibited. In addition, non-U.S. persons who engage in certain transactions with the designated individuals may themselves be exposed to sanctions, and foreign financial institutions that knowingly conduct a significant transaction for the designated persons could be subject to US correspondent or payable-through account sanctions.