Executive Order 24 June 2019 - Targeting Iran's Supreme Leader

June 2019

Iran flag web
On 24 June 2019, President Trump signed a new executive order extending the United States sanctions programme against Iran. 

Section 1 of the EO requires US persons to block the property of and refrain from entering into transactions with:

    (a) the Supreme Leader of the Islamic Republic of Iran and the Iranian Supreme Leader's Office (SLO), or
    (b) any person determined by the Secretary of the Treasury, in consultation with the Secretary of State to:

i. be a person appointed by the Supreme Leader of Iran or the SLO to a position as a state official of Iran, or as the head of any entity located in Iran or any entity located outside of Iran that is owned or controlled by one or more entities in Iran;

ii. be a person appointed to a position as a state official of Iran, or as the head of any entity located in Iran or any entity located outside of Iran that is owned or controlled by one or more entities in Iran, by any person appointed by the Supreme Leader of Iran or the SLO;

iii. have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any person whose property and interests in property are blocked pursuant to Section 1;

iv. be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly any person whose property and interests in property are blocked pursuant to this Section 1; or

v. be a member of the board of directors or a senior executive officer of any person whose property and interests in property are blocked pursuant to this section.

Section 2 of the EO authorises the Secretary of the Treasury, in consultation with the Secretary of State, to impose sanctions on a foreign financial institution which has knowingly conducted or facilitated any significant financial transaction for or on behalf of any person whose property and interests in property are blocked under Section 1.

Section 3 of the EO prohibits donations to any person whose property and interests in property are blocked under Section 1.

The term "foreign financial institution" is defined as

“…any foreign entity that is engaged in the business of accepting deposits, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent. The term includes, but is not limited to, depository institutions, banks, savings banks, money service businesses, trust companies, securities brokers and dealers, commodity futures and options brokers and dealers, forward contract and foreign exchange merchants, securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, dealers in precious metals, stones, or jewels, and holding companies, affiliates, or subsidiaries of any of the foregoing”.

Also on 24 June, OFAC announced the following SDN designations pursuant to the new EO: 

BADIN, Yadollah (a.k.a. BADIN, Yadullah), Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
GHOLAMSHAHI, Abbas (a.k.a. QOLAMSHAHI, Abbas), Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).
HAJIZADEH, Amir Ali, Iran; DOB 1961; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
KHAMENEI, Ali Husseini, Iran; DOB 19 Apr 1939; POB Mashhad, Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Ayatollah (individual) [IRAN]. 
OZMA'I, Ali (a.k.a. OZMAIE, Ali), Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
PAKPOUR, Mohammad (a.k.a. PAKPUR, Mohammad), Iran; DOB 1961; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
RAVANKAR, Mansur (a.k.a. RAVANKAR, Mansour), Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
TANGSIRI, Ali Reza (a.k.a. TANGSIRI, Alireza), Iran; DOB 1962; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).
ZIRAHI, Ramezan, Iran; DOB 1969; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).

The EO has created further ways in which transacting with Iranian entities or with entities owned or controlled by Iranian entities can give rise to an exposure to sanctions. Overall, the effect of the EO is to likely to be to further reduce the appetite of non-US persons towards conducting trade with or other activities involving Iran.