Last week the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) and the Department of State designated one individual and two entities under the Iranian Human Rights Sanctions Regulations for inclusion on the List of Specially Designated Nationals (SDN) administered by OFAC.

These parties are alleged to be at the core of Iran’s security apparatus, which in turn is accused of being responsible for or complicit in serious human rights abuses in Iran since the June 2009 disputed presidential election. The parties designated include, Iran’s Islamic Revolutionary Guard Corps (IRGC), the Basij Resistance Force (Basij), and Iran’s national police and its Chief.

The designation action was taken pursuant to Executive Order (E.O.) 13553, which targets human rights abuses engaged in by officials of the Government of Iran and persons acting on behalf of the Government of Iran. Due to the OFAC SDN designation, any property in the United States or in the possession or control of U.S. persons in which the designees have an interest is blocked, and U.S. persons are prohibited from engaging in transactions with them. These designees are also subject to visa sanctions by the Department of State.

Those seeking removal of the OFAC SDN designation would be wise to consult with an attorney who has experience in seeking such removals. There is a formal procedure for requesting a reconsideration of the designation under 31 C.F.R. 501.807. It is true that the process takes a long time, years in fact; however, SDN removals do occur and if a request for reconsideration is not sought the designation will remain intact in perpetuity. As such, once a party is designated it should seek to remove itself as quickly as possible.

The author of this blog 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.

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