The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") imposed new sanctions against Iran's Revolutionary Guard Corps ("IRGC"). The sanctions were imposed against the IRGC for their support of the IRGC-Qods Force, which Treasury Secretary Steven T. Mnuchin characterized as the "key Iranian entity enabling Syrian President Bashar al-Assad's relentless campaign of brutal violence against his own people." In addition, the sanctions were imposed for supporting designated terrorist groups including Hizballah, Hamas and the Taliban.
The IRGC was sanctioned on several different occasions for its support of Iran's ballistic missile and nuclear programs and in connection with human rights abuses. According to OFAC, the IRGC lent support to the IRGC-QF by providing training, personnel, and military equipment. IRGC members are accused of providing direct military assistance to units in Syria, and facilitating the transfer of personnel and military equipment to Iraq and Syria. The new sanctions were issued pursuant to Executive Order 13224.
OFAC also designated three Iran-based companies for contributing to Iranian missile development, and a China-based company for "proliferation activities" as a result of its activities on behalf of a key supporter of Iran's military.
Commentary / James Treanor
The re-imposition of sanctions on the IRGC was just one of the steps announced in President Trump's October 13 statement on his administration's Iran strategy. The other actions – namely, President Trump's decision not to certify that the Iran nuclear deal remains in the national security interests of the United States, and his call for Congress and U.S. allies to find ways to strengthen the agreement – could have far greater repercussions on the Iran sanctions program. These include, potentially, the eventual reinstatement of some or all of the strict pre-nuclear deal Iran sanctions prohibitions. U.S. financial institutions and corporations should have already put in place controls to prevent any dealings with the IRGC and related parties. The president's statement provides an opportunity to ensure those controls are operating effectively, and serves as a reminder that U.S. sanctions programs are constantly changing and require continuous monitoring.
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