July 31, 2019: OFAC adds Iran’s Foreign Minister to Iran sanctions

On Wednesday, OFAC added:

ZARIF, Mohammad Javad (a.k.a. ZARIF KHONSARI, Mohammad Javad; a.k.a. “ZARIF, Javad”), Iran; DOB 08 Jan 1960; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-EO13876].

to their Iran sanctions program.

And Treasury issued the following press release:

Treasury Designates Iran’s Foreign Minister Javad Zarif for Acting for the Supreme Leader of Iran

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against the Iranian regime’s Foreign Minister, Mohammad Javad Zarif (Javad Zarif), pursuant to Executive Order (E.O.) 13876 because Zarif acted or purported to act for or on behalf of, directly or indirectly, the Supreme Leader of the Islamic Republic of Iran. 

On June 24, 2019, the President issued E.O. 13876 imposing sanctions on the Supreme Leader of the Islamic Republic of Iran and the Supreme Leader’s Office (SLO), and authorizing sanctions on others associated with the Supreme Leader or the SLO.  Concurrently, Treasury added the Supreme Leader of Iran, Ali Husseini Khamenei, to OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) under this new authority.

“Javad Zarif implements the reckless agenda of Iran’s Supreme Leader, and is the regime’s  primary spokesperson around the world.  The United States is sending a clear message to the Iranian regime that its recent behavior is completely unacceptable,” said Treasury Secretary Steven T. Mnuchin.  “At the same time the Iranian regime denies Iranian citizens’ access to social media, Foreign Minister Javad Zarif spreads the regime’s propaganda and disinformation around the world through these mediums.”   

While OFAC is taking today’s action against Zarif under E.O. 13876, this new authority, additional information indicates that Javad Zarif oversees a foreign ministry that has coordinated with one of the Iranian regime’s most nefarious state entities, the IRGC-Qods Force (IRGC-QF), which is designated pursuant to terrorism and human rights authorities.  Zarif’s Ministry of Foreign Affairs and its high ranking officials have engaged in and funded efforts to influence elections, some of which have involved the IRGC-QF.  Additionally, senior officials of Iran’s Ministry of Foreign Affairs sought to facilitate the release of two IRGC-QF operatives from a foreign country by making payments to foreign judiciary officials.

Sanctions Implications

All property and interests in property of this individual that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons. 

In addition, persons that engage in certain transactions with the individual designated today may themselves be exposed to designation.  Furthermore, any foreign financial institution that knowingly conducts or facilitates a significant transaction for or on behalf of the individual designated today could be subject to U.S. correspondent account or payable-through sanctions.

Links:

OFAC Notice

Treasury Press Release

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