On January 22, 2024, the US Department of the Treasury’s Office of Foreign Assets Control imposed new designations targeting supporters of the Islamic Revolutionary Guard Corp-Qods Force (“IRGC-QF”), including Iraqi airline Fly Baghdad and its CEO for allegedly providing assistance to the IRGC-QF and related proxy groups in Iraq, Syria, and Lebanon. OFAC also identified two aircraft owned by Fly Baghdad as blocked property. In addition, OFAC designated three leaders and supporters of Kata’ib Hizballah (“KH”), one of the IRGC-QF’s main Iran-aligned militia groups in Iraq, as well as a company that allegedly moved and laundered funds for KH. According to OFAC, the designations were imposed in response to multiple drone and missile attacks carried out by KH against US personnel in Iraq and Syria following Hamas’s October 7 attack on Israel. The group has also reportedly declared its support for Hamas’s terrorism and its commitment to attacking US personnel. The IRGC-QF has been designated in the US as a Specially Designated Global Terrorist (“SDGT”) under EO 13224 since 2007 and as a Foreign Terrorist Organization (“FTO”) pursuant to the Immigration and Nationality Act since 2019. KH was also previously designated as a SDGT and a FTO in 2009.
The new designations were imposed pursuant to Executive Order 13224, as amended, which targets terrorists and their supporters. As a result of the designations, all property and interests in property of the designated persons 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 a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.
In light of the actions taken against Fly Baghdad, OFAC issued General License 27 pursuant to Global Terrorism Sanctions Regulations (“GTSR”), 31 CFR part 594. OFAC issued General License 27 to authorize, until March 22, 2024, certain civil aviation safety and wind down transactions involving Fly Baghdad. The general license also provides that any payments involving wind down transactions with Fly Baghdad are authorized as long as they are made into a blocked account in accordance with the GTSR. OFAC also issued Frequently Asked Question 1159 to provide the public with clarity on the types transactions authorized by GL 27.