Today, President Obama signed an executive order which blocked the property and interests in property, and prohibited entry into the United States of those individuals and entities alleged to be engaged in human rights abuses in Iran and Syria via the use of information technology. This is a particularly surprising move in light of the optimism surrounding the P5+1 talks in Turkey a few weeks ago.

The new sanctions, named GHRAVITY, block, and prohibit from entry to the United States those parties involved in:

1. The operation of information and communications technology that facilitates computer or network disruption, monitoring, or tracking that could enable serious human rights abuses by the Governments of Iran and/or Syria;

2. The provision of goods, services, or technology to Iran or Syria likely to be used to facilitate computer or network disruption, monitoring, or tracking that could enable serious human rights abuses by the Governments of Iran and/or Syria;

3. The provision of financial, material, or technological support for, or provision of goods or services in support of the facilitation of computer or network disruption, monitoring, or tracking that could enable serious human rights abuses by the Governments of Iran and/or Syria, or any person blocked pursuant to this executive order; or

4. Any person owned or controlled by, or acting, directly or indirectly, on behalf of any person blocked pursuant to this executive order.

Pursuant to this executive order, President Obama designated a number of entities pursuant to these new sanctions. These include: Datak Telecom, Iranian Ministry of Intelligence and Security, Islamic Revolutionary Guard Corps, Law Enforcement Forces of the Islamic Republic of Iran, Ali Mamluk, Syrian General Intelligence Directorate, and Syriatel.

As noted earlier in this posting, it is interesting that President Obama would take such a step a few weeks after reportedly successful talks with Iran in Turkey, and ahead of the continuance of those talks in Baghdad next month. A few reasons could account for this action. First, it was reported that there were recently secret talks carried on between Iran and a few Western countries in the past week. Perhaps those talks were not as fruitful as the talks in Turkey and it prompted the administration to seek tougher sanctions. Another possibility is that this latest round of sanctions, which targeted mostly those who were already sanctioned, was an attempt to appease critics of President Obama, such as Israeli Prime Minister Benjamin Netanyahu, who have opposed talks with Iran. Since these questions are really political, non-legal questions, I would love to hear thoughts from our readership who may have some additional insight into what brought on this executive order. Feel free to comment on this posting or email me.

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.