Don’t call it a comeback. On Friday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) unleashed a number of designations targeting Iranian entities under a host of authorities for activities as broad ranging as support for terrorism to evasion of sanctions by acquiring U.S. currency for the Iranian Government. These sanctions were imposed despite the fact that Iran and the P5+1 countries continue to negotiate over Iran’s disputed nuclear program, and any concessions Iran was provided through sanctions relief as part of the interim nuclear deal.

Included among these designations were a number of banks, several airlines, and shipping vessels and companies. A few of the designations were also just updates to the OFAC Specially Designated Nationals and Blocked Persons (“SDN”) List, to reflect new names being used by entities that were previously designated under different sanctions programs. The location of the targeted parties were mostly in Iran, however, some were located in Russia, Turkey, United Arab Emirates, and Thailand.

While it should be no surprise to anyone that OFAC is continuing to designate Iranian entities, what may be interesting to some is that both Meraj Airlines and Caspian Airlines were designated. The sanctions relief under the Joint Plan of Action (“JPOA”), which some refer to as the interim Iran nuclear deal, offered sanctions relief in the form of an expanded licensing policy for exports of U.S. origin aircraft parts and services to Iran. While this expanded licensing policy was general in nature, it did not include entities, except for Iran Air/Iran Airtour, designated under OFAC sanctions authorities, such as Executive Order 13382 (WMD) and 13224 (Terrorism). Meraj Airlines and Caspian Airlines are now both designated under Executive Order 13224 as Specially Designated Global Terrorists (“SDGT”), and as a result they will not fall under the sanctions relief offered by the JPOA. Why this is strange is because approximately a month ago OFAC did license the export of services to both of these airlines under the JPOA sanctions relief policy. Since OFAC carefully reviews and evaluates their designations they should have known at that time these airlines were involved in some activity which would have served as a basis of designation, and yet, they still licensed transactions with them anyway. Unless of course, OFAC just learned of those activities, and developed a designation packet for them, within the last month.

What is also surprising about the designations is that OFAC listed Caspian Airlines email address in the designation entry. While that is not, in and of itself unusual, what is unusual is that Caspian Airlines uses a Hotmail email address. First, its strange that a fully functioning airline operating in an economy as sophisticated as Iran’s would use Hotmail (No offense Microsoft) as their email provider. Second, given that the email provider, Microsoft, is a U.S. company, and there is a belief that the company is involved in terrorism, there should be a legitimate concern by Caspian that their email accounts may be subject to a search warrant and the contents thereof used in a future prosecution for terrorist activities. That assumes a lot of facts, but it is not outside of the realm of possibility.

The good news for those targeted, if any, is that there is an administrative reconsideration process to which they can avail themselves in seeking a removal of their SDN List designation. That process involves providing arguments, supported by evidence, that either a mistake was made in regards to the designation, or that there has been a change in circumstances to such an extent that the basis of designation no longer exists. For those parties designated under Executive Order 13382 the time to avail themselves of the process couldn’t be better as Iran is seeking to resolve the nuclear dispute, and there could be arguments to be made that removal would be a form of sanctions relief extended to Iran as it looks for trade offs in connection to concessions it is making on its nuclear program.