January 31, 2024

US and UK designate persons involved in the assassination of Iranian dissidents

On January 29, 2024, the US Department of the Treasury’s Office of Foreign Assets Control announced designations imposed as part of a joint action with the United Kingdom against a network led by Iranian narcotics trafficker Naji Ibrahim Sharifi-Zindashti that has allegedly engaged in the transnational repression of Iranian dissidents, journalists, and activists.  According to OFAC, Zindashti’s network operates at the direction of the Iran’s Ministry of Intelligence and Security (“MOIS”) and has carried out assassinations and kidnappings in an effort to silence critics of the Iranian regime.  The network has also allegedly plotted operations in the United States, as evidenced by an indictment of Zindashti that was unsealed by the US Department of Justice and Federal Bureau of Investigation on January 29, 2023.  The indictment relates to Zindashti’s alleged recruitment of two Canadian nationals to murder two Maryland residents, one of which had defected from Iran.

OFAC designated Zindashti and several of his key associates, including Iranian officials, who have been linked to murders in several countries, including the United Arab Emirates, Canada, and Türkiye.  These designations were impose pursuant to Executive Order 13553 for providing assistance to Zindashti or the MOIS.  The MOIS has been designated in the US since 2012, pursuant to EO 13553 for engaging in serious human rights abuse against the Iranian people since June 12, 2009; under the US counterterrorism authority, EO 13224, for supporting Hizballah, Hamas and Al-Qa’ida; and pursuant to EO 13572 for supporting those responsible for human rights abuse in Syria.  As a result of these designations, all property and interests in property of the 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 designated persons.  Entities owned 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for a designated person risk exposure to sanctions.

In addition to the designation of Zindashti and members of his network, UK authorities designated Mohammed Ansari and Muhammed Abd Al-Razek Kanafani, two Iranian officials allegedly responsible for a threat to kill two television presenters from news channel Iran International on UK soil.  The UK government reported that Ansari and Kanafani were both members of Islamic Revolutionary Guard Corps (“IRGC”) Unit 840, an entity that was also sanctioned.  The designations were imposed under the Iran (Sanctions) Regulations 2023 (SI 2023/1314), which subjects listed persons to asset freezes and travel bans in the United Kingdom.

US Department of Treasury Press Release | US DOJ Press Release – Indictment | Zindashti Indictment | UK Government Press Release | OFSI Financial Sanctions Notice – Iran