On November 23, 2022, the US Department of the Treasury’s Office of Foreign Assets Control announced that it designated three officials who oversee Kurdish cities in northwestern Iran, including Sanandaj and Mahabad, for imposing extreme measures in this region in an effort to end ongoing protests held in response to the September 2022 killing of Mahsa Amini by Iran’s “morality police.” OFAC reports that it designated the governor of Sanandaj, the commander of the Law Enforcement Forces of the Islamic Republic of Iran (“LEF”) in Sanandaj, and the ground forces commander of the Islamic Revolutionary Guard Corps (“IRGC”) over the West Azerbaijan province, which includes the city of Mahabad, for imposing a lockdown on Iranian citizens in these cities, which has caused severe disruptions to their internet and telephone services and also impacted their water supply. The LEF and the IRGC were both designated in 2011 under Executive Order 13553, which targets persons who have committed serious human rights abuses involving Iran, for engaging in the suppression of protestors’ free speech and supporting the extrajudicial killing and torture of unarmed protestors following Iran’s disputed presidential election in June 2009. The three newly-designated officials were sanctioned pursuant to EO 13553, for having acted or purported to act on behalf of the IRGC or the LEF.
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.