March 9, 2023

US, UK, and EU impose coordinated sanctions to mark International Women’s Day

On March 8, 2023, also known as International Women’s Day, the US Department of the Treasury’s Office of Foreign Assets Control designated 8 officials and 3 entities in Iran responsible for serious human rights abuses against women and girls. OFAC reports that the International Women’s Day sanctions were coordinated with the EU, UK and Australia in an effort to demonstrate their unified commitment to holding the Government of Iran accountable for denying Iranian women and girls their human rights and dignity.  Accordingly, OFAC sanctioned 3 Iranian companies and their leaders who supported the repression of peaceful protestors by Iranian Law Enforcement Forces (“LEF”) and several Iranian leaders, including a leader of the Islamic Revolutionary Guard Corps (“IRGC”). OFAC also designated two senior-level Iranian prison officials – Ali Chaharmahali, the director general of Alborz Province Prisons, and Dariush Bakhshi, the head of Orumiyeh Central Prison in West Azerbaijan Province.  According to OFAC, Chaharmahali manages the Evin Prison that frequently uses threats of rape as a form of coercion upon its female inmates – a prison that also allegedly lacks health services for women and has denied their access to medical care.  OFAC states that it designated Bakhshi for overseeing Orumiyeh Central Prison for allegedly subjecting its female inmates, including peaceful protestors, to sexual violence and other forms of mistreatment by prison officials and IRGC interrogators.  All OFAC designees were sanctioned pursuant to Executive Order 13553, which targets persons involved in serious human rights abuses by the Government of Iran, or EO 13846, which targets those engaged in censorship and related activities in Iran.

As a result of the US 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.

On the same day, the UK marked International Women’s Day by targeting gender-based violence in Iran, Syria, South Sudan and the Central African Republic. Foreign Secretary James Cleverly, who was in Sierra Leone to launch the new Foreign, Commonwealth and Development Office (“FCDO”) Women and Girls Strategy (a program established to tackle gender inequality around the world), announced the new package of sanctions which designated 4 individuals and 1 entity, including the Headquarters for Enjoining Right and Forbidding Evil in Iran, a government institution responsible for enforcing mandatory dress codes for women in Iran, and its head official Seyyed Mohammed Saleh Hashemi Golpayegani.  The UK also sanctioned others responsible for serious human rights abuses, including a commander of the South Sudan People’s Defenses Forces accused of using sexual and gender-based violence in Tambura County in 2021 and a member of the “227 Region Branch” involved in the repression of civilians in Syria through systematic killing and rape.

The new UK designations were imposed by HM Treasury’s Office of Financial Sanctions Implementation under The Iran (Sanctions) (Human Rights) (EU Exit) Regulations 2019 (SI 2019/134); The Syria (Sanctions) (EU Exit) Regulations 2019 (SI 2019/792); and The South Sudan (Sanctions) (EU Exit) Regulations 2019 (SI 2019/438), all of which subject designees to asset freezes and travel bans.

On March 7, 2023, just ahead of International Women’s Day, the Council of the EU imposed restrictive measures, including assets freezes and travel bans, upon 9 individuals and 3 entities accused of committing serious human rights violations and abuses and, in particular, sexual and gender-based violence.  Among those sanctioned are two acting Taliban ministers responsible for banning women from higher education and certain gender-segregated practices in public spaces and Iran’s Qarchak Prison where guards allegedly torture and rape female detainees, including political prisoners and peaceful protestors, and deny them access to clean drinking water, food, and medical assistance.  All EU sanctions were imposed following the adoption of Council Implementing Regulation (EU) 2023/500 and Council Decision (CFSP) 2023/501, which targets serious human rights violations and abuses.

US Department of  Treasury Press Release | UK Government Press Release | OFSI Financial Sanctions Notice – Iran (Human Rights) | OFSI Financial Sanctions Notice – South Sudan | OFSI Financial Sanctions Notice – Syria | Council of the EU Press Release | Council Implementing Regulation (EU) 2023/500 | Council Decision (CFSP) 2023/501