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OFAC Issues More Iran SDN Designations for the Second Day in a Row
March 28, 2012 For the second day in a row the United States Department of the Treasury's Office of Foreign Assets Control (OFAC) has designated individuals and entities in Iran under one of their sanctions programs. Today, OFAC designated two individuals and four entities pursuant to Executive Order 13382 and the Non-Proliferation of Weapons of Mass Destruction Sanctions. This differs from yesterday's designations which were made pursuant to Executive Order 13224 and the Global Terrorism Sanctions. Executive Order (E.O.) 13382 is the legal authority OFAC utilizes to freeze the assets of those they believe to be proliferators of weapons of mass destruction (WMD) and their supporters. OFAC does this to isolate such individuals and entities from the U.S. financial and commercial systems. Today's action involved the designation of the following parties: 1. Iran Maritime Industrial Company SADRA (SADRA); 2. Deep Offshore Technology PJS; 3. Malship Shipping Agency Ltd.; 4. Modality Limited; 5. Seyed Alaeddin Sadat Rasool; and 6. Ali Ezati OFAC has accused the above parties of being involved with either the Iranian Revolutionary Guards Corps or the (IRISL), two organizations which have previously been designated by OFAC. In its press release OFAC has acknowledged that the IRGC has continued to expand its control over the Iranian economy, stating that "in particular in the defense production, construction, and oil and gas industries subsuming increasing numbers of Iranian businesses and pressing them into service in support of the IRGC's illicit conduct." Many critics of the country based sanctions program maintained against Iran state that the reason the IRGC has been able to gain more influence in the Iranian economy is because the private sector has been stripped away due to the impact the broad based trade embargo imposed against Iran have had. What is most notable about these designations is what I commented upon yesterday when the other Iranian entities were designated; namely, that the sanctions seem to be increasingly directed towards Iran's transportation industry. Again, today we see a number of designations of those parties alleged to be affiliated with IRISL, an entity involved in the transportation industry. OFAC has long touted the success of their designations against IRISL, these recent designations make it seem as if they plan on sticking to that strategy as they believe it is yielding results.

The author of this article is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.