On January 23, 2023, the US Department of the Treasury’s Office of Foreign Assets Control designated Iran’s Islamic Revolutionary Guard Corps (“IRGC”) Cooperative Foundation and five of its board members, Deputy Minister of Intelligence and Security Naser Rashedi, and four IRGC officers in Iran. The designations were imposed in coordination with the United Kingdom and the European Union in an effort to target senior security officials and key sectors of the IRGC responsible for funding the Iranian government’s brutal suppression of its people. OFAC imposed these designations pursuant to Executive Order 13553, which enables the US to sanction persons who participate in 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.
UK Foreign Secretary James Cleverly also announced the imposition of sanctions upon several officials and entities in Iran, including Deputy Prosecutor General Ahmad Fazelian, who is responsible for the judicial system that has imposed egregious punishments for political purposes. This comes just over a week after the United Kingdom sanctioned Iran’s Prosecutor General Mohammad Jafar Montazeri following the execution of British-Iranian dual national Alireza Akbari. Among the new designees is the Basij Resistance Force, a group within the IRGC responsible for the violent repression on the streets of Iran, along with the group’s Deputy Commander Salar Abnoush. The new designations were imposed pursuant to The Iran (Sanctions) (Human Right) (EU Exit) Regulations 2019 (SI 2019/134), and all new designees are now subject asset freezes in the UK.
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.