On December 21, 2022, the US Department of the Treasury’s Office of Foreign Assets Control imposed sanctions upon Mohammad Jafar Montazeri, Iran’s Prosecutor General, and certain key military and paramilitary officials in Iran responsible for the continuing and escalating violence against protestors throughout Iran. According to OFAC, in the past two weeks, two protestors were executed and several were sentenced to death, following the documented use of torture to obtain confessions.
In total, OFAC designated five Iranian officials and one entity, the Imen Sanat Zaman Fara Company (“Imen Sanat”), responsible for manufacturing and providing anti-riot equipment to Iran’s Law Enforcement Forces (“LEF”), and in particular, the LEF Special Units, one of the main protest suppression forces. The LEF and the LEF Special Units were previously designated by OFAC pursuant to Executive Order 13553 in 2011 and 2021, respectively. EO 13553 enables the US to sanction persons who participate in certain serious human rights abuses by the Government of Iran against persons in Iran or Iranian citizens, on or after June 12, 2009, regardless of where the abuses occur. According to OFAC, Imen Sanat produces automatic grenade launchers, bulletproof vests, shields and other items used by Iranian security forces to suppress protestors. OFAC further reports that there is recent video and photographic evidence of Iranian security forces attempting to run over protestors using armored vehicles produced by Iman Sanat, in an effort to suppress the nationwide protests. The new designations are imposed pursuant Executive Order 13553.
As a result of these designations, all property and interests in property of these 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.