US Designations in Respect of Iran Sanctions – November 2020

On 18 November 2020, US OFAC announced the designation for sanctions of a large number of companies and individuals in connection with its sanctions programme targeting Iran. The designations are based on US secondary sanctions authorities, meaning that restrictions, and a potential exposure to sanctions, will likely apply to non-US persons.

In large part, the list consists of individuals and entities connected with “Islamic Revolution Mostazafan Foundation (Bonyad Mostazafan)”, which according to an OFAC press release is:

“…an immense conglomerate of some 160 holdings in key sectors of Iran’s economy, including finance, energy, construction, and mining. While Bonyad Mostazafan is ostensibly a charitable organization charged with providing benefits to the poor and oppressed, its holdings are expropriated from the Iranian people and are used by the Supreme Leader Ali Khamenei to enrich his office, reward his political allies, and persecute the regime’s enemies.”

Many shipping/energy-related companies are included in the new designations, including Sina Port and Marine Services Development Company, which is reported to operate container terminals at Bandar Abbas previously operated by the already designated Tidewater Middle East. In addition it is worth noting that many of the listed companies appear to be involved with trades that have not been specifically targeted for sanctions previously (such as textiles and ceramics). This may yet further restrict trade to/from Iran, and create additional issues in respect of due diligence. A complete list of the latest designations can be found here.