On Friday 3 February, US Treasury added 13 persons and 12 companies to the OFAC’s SDN List. The sanctions are a stand against Iran’s recent ballistic missile test. According to OFAC, the sanctions are aimed at persons and companies “procuring technology and/or materials to support Iran’s ballistic missile program, as well as for acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)”. Among the sanctioned parties are Chinese and Libanese companies. OFAC furthermore states that the sanctions reflect “the United States’ commitment to enforcing sanctions on Iran with respect to its ballistic missile program and destabilizing activities in the region and is fully consistent with the United States’ commitments under the Joint Comprehensive Plan of Action (JCPOA)”. An overview of the sanctioned parties can be found here. The US Treasury’s press release can be found here. The sanctions follow a strong condemnation by US President Trump of the missile test, putting Iran “on notice”. However, it is noted that this was only an informal condemnation and that the US has not (yet) triggered any formal procedure of withdrawal of or from the JCPOA.
In response to the additional US sanctions, Iran’s ministry of foreign affairs has stated that the US sanctions were “illegal” and “illegitimate” and that Iran is considering to impose restrictions on American entities and individuals who “have created and helped terrorist groups?[…]?and killings and suppression of defenseless civilians” in the Middle East. Also, on Saturday 4 February, Iran tested yet another ballistic missile, defying the new US sanctions. As stated above, no formal procedure under the JCPOA has been started. Should this change, we will inform you. Should you have any questions related to the Iran sanctions, please contact us at info@balaw.nl or +31 (0) 20 2600082