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Yesterday at OFAC: Iran addition, Nicaragua & Venezuela removals, counter terror updates, and a new Russia FAQ

OFAC today added the following individuals:

HASSANZADEH, Hassan (a.k.a. HASSANZADEH, Hasan (Arabic: حسن حسنزاده)), Tehran, Iran; DOB 21 Mar 1957; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; IRGC Brigadier General (individual) [IRGC] [IRAN-HR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

HOSSEINI, Seyed Sadegh (Arabic: سید صادق حسینی) (a.k.a. HOSSEINI, Sadegh), Kurdistan, Iran; DOB 1963 to 1964; POB Dehloran, Iran; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; IRGC Commander in Kurdistan (individual) [IRGC] [IRAN-HR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).

MAROUFI, Hossein (Arabic: حسین معروفی) (a.k.a. MAROOFI, Hossein), Iran; DOB 1965 to 1966; POB Shahr-e Babak, Kerman province, Iran; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Deputy Coordinator of the Basij (individual) [IRGC] [IRAN-HR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).

MOEIN, Moslem (Arabic: مسلم معین) (a.k.a. MO'IN, Moslem), Part 7, Block 25, Ground Floor, 16th Street, Sarvestan Street, Chaghamirza Phase 2 Shahid Mehrabi, Kermanshah, Iran; DOB 22 Sep 1985; POB Eslamabad, Iran; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 3341588477 (Iran); Birth Certificate Number 3477 (Iran) (individual) [IRAN-HR] (Linked To: BASIJ RESISTANCE FORCE).

MONTAZERI, Mohammad Jafar (Arabic: محمد جعفر منتظری), Iran; DOB 21 Jan 1949 to 19 Feb 1949; POB Qom, Iran; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Attorney General of Iran; Prosecutor General of Iran (individual) [IRAN-HR].

and entity:

IMEN SANAT ZAMAN FARA COMPANY (Arabic: شرکت ایمن صنعت زمان فرا), Shahrak-e-Jafar Abad-e-Jangal Rd, Naseriyeh, Tehran, Iran; Number 16, Kolezar alley, Farsian Street, Shahid Rezaiee Street, Azadegan Autobahn, Tehran, Iran; Number 16, Gholshan 14, Golestan Boulevard, Negarestan Boulevard, Sham Abad, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions; National ID No. 103201991293 (Iran); Business Registration Number 369541 (Iran) [IRAN-HR] (Linked To: LAW ENFORCEMENT FORCES OF THE ISLAMIC REPUBLIC OF IRAN). 

under its Iran sanctions authority, and removed the following:

CASTILLO CASTILLO, Orlando Jose (a.k.a. CASTILLO, Orlando), Residencial Bolonia, Canal 2 1 Cuadra Al Sur 3 C Al Oeste, Managua, Nicaragua; DOB 02 Sep 1943; POB Esteli, Nicaragua; nationality Nicaragua; Gender Male; Passport C01713933 (Nicaragua) issued 24 Jul 2014 expires 24 Jul 2024; National ID No. 1610209430002G (Nicaragua) (individual) [NICARAGUA]. 

CASTILLO, Orlando (a.k.a. CASTILLO CASTILLO, Orlando Jose), Residencial Bolonia, Canal 2 1 Cuadra Al Sur 3 C Al Oeste, Managua, Nicaragua; DOB 02 Sep 1943; POB Esteli, Nicaragua; nationality Nicaragua; Gender Male; Passport C01713933 (Nicaragua) issued 24 Jul 2014 expires 24 Jul 2024; National ID No. 1610209430002G (Nicaragua) (individual) [NICARAGUA].

from the Nicaragua program, the following:

N488RC; Aircraft Model G200; Aircraft Manufacturer's Serial Number (MSN) 228; Aircraft Tail Number N488RC (aircraft) [VENEZUELA] (Linked To: SARRIA DIAZ, Rafael Alfredo). 

from the Venezuela program, and updated the following counter terrorism listings:

BAYALTUN, Ahmet, Turkey; DOB 1971; citizen Turkey; Gender Male (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT). -to- BAYALTUN, Ahmet, Atlikonak Mahallesi, Atlikonak Sokak, No:13, Eyyubiye, Shanliurfa, Turkey; DOB 21 Nov 1989; POB Akcakale, Turkey; nationality Turkey; citizen Turkey; Gender Male; Identification Number 43942946562 (Turkey) (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT). 

BAYALTUN, Ismail (a.k.a. BAYALTUN, Ismail Halil), Dunya Is Mer, Gaziantep, Turkey; No:/A Atlikonak, Sanliurfa 63000, Turkey; DOB 01 Oct 1989; alt. DOB 21 Nov 1980; citizen Turkey; Gender Male; National ID No. C13638980 (Turkey); Identification Number 4386794904 (Turkey) (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT). -to- BAYALTUN, Ismail (), Atlikonak Koyu Koyichi Shanliurfa, Merkez, Shanliurfa, Turkey; DOB 21 Nov 1980; POB Akcakale, Turkey; nationality Turkey; citizen Turkey; Gender Male; Identification Number 43951946270 (Turkey) (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

It also published one new Russia-related Frequently Asked Question (FAQ):

RUSSIAN HARMFUL FOREIGN ACTIVITIES SANCTIONS

1109. Are petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading for maritime transport prior to February 5, 2023 subject to the price cap?

Answer

No, provided the petroleum products are unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023.  Petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, February 5, 2023, and unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023, are not subject to the price cap.  U.S. service providers can continue to provide services related to the maritime transport of petroleum products of Russian Federation origin purchased at a price above the price cap, provided that the petroleum products are loaded onto a vessel at the port of loading for maritime transport prior to 12:01 a.m., eastern standard time, February 5, 2023, and unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023.

The following is an example of a permissible transaction: 

  • A U.S. commodities trader signs a contract on January 1, 2023, to purchase petroleum products of Russian Federation origin for shipment to a jurisdiction that has not prohibited the import of such petroleum products.  The U.S. commodities trader arranges for the petroleum products to be loaded onto a vessel at the port of loading.  The vessel is loaded on February 1, 2023, and a bill of lading is issued.  The petroleum products are shipped and discharged at the port of destination on February 15, 2023.  U.S. insurance companies provide cover for this shipment/voyage and pay out any related claims, as appropriate.

OFAC anticipates implementing the price cap on petroleum products of Russian Federation origin by publishing a determination pursuant to Executive Order 14071 that (i) permits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of services related to the maritime transport of petroleum products of Russian Federation origin, where the price of such petroleum products of Russian Federation origin do not exceed the price cap and (ii) prohibits such services if the petroleum products of Russian Federation origin are purchased above the relevant price cap.  This determination would take effect at 12:01 a.m., eastern standard time, February 5, 2023, with respect to maritime transport of petroleum products of Russian Federation origin loaded on or after 12:01 a.m., eastern standard time, February 5, 2023. 

Date Released

December 21, 2022

Frequently Asked Question 1109

And Treasury:

PRESS RELEASES

Treasury Sanctions Iranian Regime Officials Tied to Continued Violence Against Protestors 

December 21, 2022

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting the Prosecutor General and key military and paramilitary officials in Iran, as well as a company manufacturing and providing Iran’s Law Enforcement Forces with anti-riot equipment. As nationwide protests continue throughout Iran, the response from Iranian security forces has continued to escalate. In the past two weeks, two protestors have been executed, one publicly, and several others have been sentenced to death. Today’s action targets the senior official overseeing the prosecution of protestors, as well as leaders of military and paramilitary organizations violently cracking down and detaining protestors and a company that procures and provides security forces with tools of suppression.

“We denounce the Iranian regime’s intensifying use of violence against its own people who are advocating for their human rights,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States and our partners are dedicated to holding Iranian officials to account for egregious abuses committed against Iranian citizens fighting for their fundamental freedoms.” 

Today’s actions are taken pursuant to Executive Order (E.O.) 13553, which authorizes the imposition of sanctions on persons with respect to certain serious human rights abuses by the Government of Iran, an official of the Government of Iran, or a person acting on behalf of the Government of Iran, and follows a series of designations targeting key members of the Iranian state apparatus responsible for the crackdown on peaceful demonstrators, including Islamic Revolutionary Guard Corps (IRGC) Intelligence Organization Commander Mohammad Kazemi and Deputy Commander for Operations Abbas Nilforushan.  

MOHAMMAD JAFAR MONTAZERI

Mohammad Jafar Montazeri (Montazeri), Iran’s Prosecutor General, also referred to as the Attorney General, oversees prosecutions and the enforcement of criminal judgments throughout Iran, including such actions brought in Iran’s Revolutionary Courts, the primary venue for charging those arrested in the protests. In late September, Montazeri issued a directive to courts to act “decisively” and issue harsh sentences to many of those arrested during the ongoing protests. The case of the first executed protestor, a young man named Mohsen Shekari, proceeded with little resemblance to a meaningful trial, according to multiple international sources. Mr. Shekari was charged with blocking a street and attacking a security force member in Tehran who needed stitches. There is evidence that Mr. Shekari was tortured and denied access to a lawyer. He was executed less than three weeks after his conviction. 

Observers have consistently documented the use of torture by Iranian authorities during investigations for the purpose of extracting confessions. Defendants reportedly have also been denied the right to be represented by counsel during trials before the Revolutionary Courts. Iranian authorities have used sham Revolutionary Court trials to issue at least a dozen death sentences for protesters. Dozens more, including persons under the age of eighteen years old, are expected to be tried on capital charges in connection with protests. 

Montazeri is being designated pursuant to E.O. 13553 for being an official of the Government of Iran or a person acting on behalf of the Government of Iran (including members of paramilitary organizations) who is responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses against persons in Iran or Iranian citizens or residents, or the family members of the foregoing, on or after June 12, 2009, regardless of whether such abuses occurred in Iran.

IMEN SANAT ZAMAN FARA COMPANY

Iranian company Imen Sanat Zaman Fara manufactures numerous types of equipment for Iran’s Law Enforcement Forces (LEF), and in particular, the LEF Special Units, one of the Islamic Republic’s main protest suppression forces. Treasury designated the LEF pursuant to E.O. 13553 on June 9, 2011, for its role in the 2009 post-election crackdown, and the LEF Special Units pursuant to E.O. 13553 on December 7, 2021, for being persons acting on behalf of the Government of Iran responsible for or complicit in the commission of serious human rights abuses against persons in Iran or Iranian citizens.

Among other equipment, the Imen Sanat Zaman Fara Company produces armored vehicles, also described as “tactical” vehicles, for use in crowd suppression. During the recent nationwide protests, video and photographic evidence has illustrated Iranian security forces using armored vehicles to suppress protests and, in some cases, attempt to run over protestors. LEF Special Units commander Hassan Karami explicitly lauded the use of Imen Sanat Zaman Fara Company armored vehicles in protest suppression. Imen Sanat Zaman Fara Company also produces automatic grenade launchers, bulletproof vests, shields, and other products used by security forces in protest suppression. 

Imen Sanat Zaman Fara Company is being designated pursuant to E.O. 13553 for materially assisting, sponsoring, or providing financial, material, or technological support for, or goods or services to or in support of, the LEF, a person whose property and interests in property are blocked pursuant to E.O. 13553.

IRGC AND BASIJ SENIOR OFFICIALS

OFAC is also designating two senior officials of Iran’s Basij Resistance Forces, a paramilitary organization controlled by Iran’s Islamic Revolutionary Guard Corps (IRGC). Moslem Moein (Moein), as chief of the Basij Cyberspace Headquarters, oversees efforts to control and censor Iranians’ online activities. He has spoken publicly about the Basij’s priority to monitor Iranians’ use of the internet. Additionally, Moein has advocated for the development of Iran’s national intranet, which could allow the regime to disconnect Iran from the global internet. The Iranian government continues to filter and block the free flow of information in Iran.

As the recently appointed Deputy Coordinator of the Basij, Hossein Maroufi (Maroufi) has played a role in the Basij’s violent response to the protests. Maroufi was also involved in the regime’s crackdown in 2019 during nationwide protests stemming from a rise in gasoline prices. In his role as the IRGC Commander of Golestan Province during this time, Maroufi was allegedly responsible for ordering the use of deadly weapons against Iranian protestors, as well as orchestrating mass arrests of demonstrators. 

Moein is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Basij, a person whose property and interests in property are blocked pursuant to E.O. 13553. Maroufi, is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC, a person whose property and interests in property are blocked pursuant to E.O. 13553.

Today’s action further targets two IRGC officials, Hassan Hassanzadeh (Hassanzadeh), the commander of IRGC forces in Tehran, and Seyed Sadegh Hosseini (Hosseini), the commander of the Beit-al Moghadas Corps and IRGC Commander in Kurdistan.

As commander of IRGC forces in Tehran, Hassanzadeh has overseen the crackdown against protests in the city. During the recent demonstrations in Tehran, Hassanzadeh announced that many protestors had been captured, claiming that Basij members had been targeted, and that weapons were confiscated. IRGC forces in Tehran have arrested protestors to allegedly defend the Islamic Republic’s centers of power. 

Hosseini, in his role as the IRGC Commander in Kurdistan, has spoken out strongly against protestors in the region he oversees. Hosseini was also involved in the regime’s crackdown during the November 2019 protests shortly after he became the IRGC Commander in Kurdistan and began serving on the Provincial Security Council. During this period, Hosseini authorized the use of deadly force against unarmed protestors and ordered the mass arrest of demonstrators, leading to the death of at least seven people.  

Hassanzadeh and Hosseini are being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC, a person whose property and interests in property are blocked pursuant to E.O. 13553.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions 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 persons designated today may themselves be exposed to sanctions or subject to an enforcement action. Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897. Detailed information on the process to submit a request for removal from an OFAC sanctions list.

U.S. Treasury Department Press Release

and State:

Sanctioning Iranian Officials Connected to Serious Human Rights Abuses

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

DECEMBER 21, 2022

Since protests erupted across Iran in September, the Iranian regime has responded with ruthless crackdowns on peaceful protestors in an effort to suppress the Iranian people’s voices.  Iranian authorities have killed hundreds of peaceful protestors, including dozens of children, and arbitrarily detained thousands, in addition to using sexual violence against protestors, according to extensive and credible reports.  Iranian courts issued harsh sentences to protestors, including the death penalty, following sham trials lacking fair trial guarantees.

Today, we are taking additional actions to confront these human rights abuses by designating five Iranian officials and one entity, pursuant to Executive Order 13553, which authorizes sanctions with respect to serious human rights abuses by the Government of Iran.  Specifically, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Mohammad Jafar Montazeri, the Prosecutor-General of Iran; Moslem Moein, the chief of the Basij Cyberspace Headquarters; Hassan Hassanzadeh, the commander of IRGC forces in Tehran; Seyed Sadegh Hosseini, the commander of the IRGC’s Beit-al Moghadas Corps of Kurdistan province; and Hossein Maroufi, the Deputy Coordinator of the Basij.

Additionally, OFAC is designating Imen Sanat Zaman Fara Company, an Iranian manufacturer of armored vehicles, tactical gear, and other materials that are actively used by the Iranian Law Enforcement Forces and other Iranian security forces in protest suppression.

The United States continues to support the people of Iran in the face of this brutal repression, and we are rallying growing international consensus to hold the regime accountable. Thousands of brave Iranians have risked their lives and their liberty to protest the regime’s long record of oppression and violence. We again call on Iran’s leadership to immediately cease its violent crackdown and to listen to its people. We will continue to promote accountability for those involved as we support the Iranian people.

U.S. State Department Press Release

issued press releases about the Iran designations.

Links:

OFAC Notice

New FAQ 1109

Press Releases – Treasury, State

Categories: Frequently Asked Questions (FAQ) Guidance Iranian Sanctions Nicaragua sanctions OFAC Updates Russian Harmful Foreign Activities Sanctions Sanctions Lists Terrorism Venezuela sanctions

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