United States Imposes Additional Sanctions against Iran

President Donald J. Trump issued a new Executive Order imposing sanctions against the Supreme Leader of Iran in response to a "series of provocative actions in recent weeks, leading up to the attack on a United States drone operating over international waters." The White House press release also cited Iran's nuclear-related activities, including plans to increase its stockpile of enriched uranium, as key precipitating events.

The Executive Order authorizes the U.S. Treasury Department to impose sanctions on additional Iranian officials, and it was reported that the Secretary of the Treasury indicated that Treasury will target Iranian Foreign Minister Mohammad Javad Zarif with sanctions later this week. Sanctions also are authorized on any foreign financial institution that knowingly conducts or facilitates a significant financial transaction for, or on behalf of, an individual or entity designated pursuant to the Executive Order.

Separately, OFAC designated eight senior commanders in the Islamic Revolutionary Guard Corps ("IRGC"), pursuant to Executive Order 13224, in connection with the IRGC's alleged involvement in (i) the recent downing of the U.S. drone, (ii) the "harassment and sabotage" of commercial vessels and (iii) destabilizing activities in Syria.

As a result of these sanctions, all property and interests in property of the designated individuals in the United States are now blocked and must be reported to OFAC. All U.S. persons generally are prohibited from dealings that involve these individuals or their property interests.

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