On October 26, 2022, only 40 days after the death of Mahsa Amini while in the custody of Iran’s Morality Police, the US Department of the Treasury’s Office of Foreign Assets Control designated 12 Iranian officials and 2 Iranian entities responsible either for the violent repression of nationwide protests in Iran or the Iranian government’s efforts to disrupt the digital freedom of its citizens. Among the designees are leaders in the Islamic Revolutionary Guards Corps Intelligence Organization (“IRGC IO”) who engaged in the brutal suppression of protestors, and several Iranian prison officials who manage prisons where protestors have allegedly been subjected to torture and other forms of physical abuse. OFAC also designated Seyed Mojtaba Mosafavi and Farzin Karimi, 2 members of Iran’s Ministry of Intelligence and Security (“MOIS”) who co-founded the Ravin Academy, which has allegedly served as a training ground for cyber hackers, many of which have been recruited by MOIS. In addition, the Samane Gostar Sahab Pardaz Private Limited Company, one of Iran’s main providers of social media filtering services, was also designated for allegedly providing the Government of Iran with tools to censor and surveil its citizens and analyze their private data.
OFAC imposed these designations pursuant to Executive Order 13553, which targets persons involved in serious human rights abuses by the Government of Iran; EO 13846, which targets persons who engage in censorship or other activities in Iran; and EO 13606, which targets grave human rights abuses by the Governments of Iran and Syria via information technology.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned 50 percent or more by one or more blocked persons are also blocked, and any foreign financial institution that knowingly conducts or facilitates a significant transaction for, or on behalf of, a blocked person could be subject to US correspondent or payable-through account sanctions.