The Department of the Treasury Office of Foreign Assets Control ("OFAC") designated nine Iranian individuals and entities under Executive Order 13224 (Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten to Commit, or Support Terrorism). The designation stems from a joint action by the U.S. and United Arab Emirates ("UAE") against an alleged illicit Iranian currency exchange network.
Treasury Secretary Steven T. Mnuchin stated that the Iranian regime, including Iran's Central Bank, abused access to entities in the UAE in order to acquire U.S. dollars to fund the Islamic Revolutionary Guard Corps-Qods Force's ("IRGC-QF") "malign activities, including to fund and arm its regional proxy groups, by concealing the purpose for which the U.S. dollars were acquired." The designated Iranian individuals and entities "procured and transferred millions to the IRGC-QF" using a large-scale currency exchange network.
All property and interests in property of the individuals and entities designated are blocked subject to U.S. jurisdiction, and U.S. persons generally are prohibited from nearly all dealings with them. In addition, non-U.S. persons who continue to have dealings with the designated parties risk exposure to "secondary sanctions," which could include a prohibition on access to the U.S. financial system or the blocking of property under U.S. jurisdiction.