On July 19, the P5+1 (the US, UK, Germany, France, Russia, and China) and Iran affirmed that they will continue to implement their commitments under the Joint Plan of Action (JPOA). Accordingly, the United States and European Union extended through November 24, 2014, the sanctions relief provided for in the JPOA as the two sides work towards concluding a long-term agreement on Iran's nuclear program. In addition to extending the suspension of sanctions targeting Iran's civil aviation, automotive, petrochemical, and precious metal sectors, the United States and European Union will continue to temporarily halt their efforts to further reduce Iran's crude oil exports. They have also agreed to permit Iran to access an additional $2.8 billion in restricted funds.

Despite extending the JPOA deadline, OFAC emphasized that it will continue to vigorously enforce non-suspended sanctions against Iran, including by taking action against those who attempt to evade or circumvent such sanctions. Accordingly, on August 29, OFAC targeted 28 entities and individuals under various Iran-related sanctions authorities, including those aimed at Iran's missile and nuclear programs, sanctions evasion efforts, and support for terrorism.

Specifically, OFAC designated:

  • Four individuals and two entities pursuant to E.O. 13382, which targets proliferators of weapons of mass destruction and their supporters. The named persons are Mohammad Javad Imanirad, Arman Imanirad, Nefertiti Shipping, Sazeh Morakab, Ali Gholami, and Marzieh Bozorg. OFAC also identified two aliases used by Shahid Hemat Industrial Group, a previously sanctioned key Iranian missile proliferator—Sahand Aluminum Parts Industrial Company and Ardalan Machineries Company.
  • Two entities, three individuals, and six vessels involved in Iran's energy industry pursuant to E.O. 13645, which implemented certain sanctions set forth in the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) and introduced additional sanctions targeting Iran. The newly designated persons include Faylaca Petroleum, Abdelhak Kaddouri, Muzzafer Polat, Seyedeh Hanieh Seyed Nasser Mohammad Seyyedi, and Lissome Marine Services LLC, which owns the six identified vessels. Lissome Marine Services is alleged to have facilitated ship-to-ship transfers of crude oil to circumvent sanctions. The other designated persons are accused of acting for, on behalf of, or otherwise being affiliated with the Government of Iran, including the National Iranian Oil Company and Naftiran Intertrade Company.
  • Asia Bank (formerly Chemeximbank) pursuant to E.O. 13622 for its provision of material support to the Central Bank of Iran in connection with the purchase or acquisition of US dollar notes by the Government of Iran. Amongst other provisions, E.O. 13622 authorizes sanctions on any person determined to have materially assisted or provided support for the Central Bank or Iran or the purchase or acquisition of US bank notes by the Government of Iran. OFAC alleges that Asia Bank changed its name in order to facilitate the delivery of more than $13 million worth of US banknotes from Russia into Iran. This is the first time that OFAC targeted a bank for supplying US banknotes into Iran.
  • Five Iranian banks subject to sanctions under E.O. 13599, which blocks the property and interests of property of the Government of Iran and Iranian financial institutions. The now-designated banks are Khavarmianeh Bank, Ghavamin Bank, Gharzolhasaneh Resalat Bank, Kish International Bank, and Kafolatbank.
  • Four entities and one individual pursuant to E.O. 13224 in connection with Iran's support for terrorist activities. Meraj Air, Caspian Air, Sayyed Jabar Hosseini, Pioneer Logistics, and Asian Aviation Logistics were allegedly involved in ferrying cargo and/or personnel into Syria and elsewhere to help the Assad regime or terror groups. OFAC also identified the alias Pouya Air as being used by Yas Air, an Iranian airline previously sanctioned under this authority.

The Department of State simultaneously announced additional actions under its authorities, imposing sanctions on four companies pursuant to E.O. 13382: the Organization of Defensive Innovation and Research, the Nuclear Science and Technology Research Institute, Jahan Tech Rooyan Pars, and Mandegar Baspar Kimiya Company. The State Department also imposed sanctions pursuant to the IFCA on Goldentex FZE, a U.A.E.-based company involved in providing support to Iran's shipping sector. Finally, the State Department imposed sanctions on Italy-based Dettin SpA pursuant to the Iran Sanctions Act of 1996, as amended, for knowingly providing Iran's petrochemical industry with goods and support whose value exceeded $250,000. The State Department emphasized that while the JPOA authorizes Iran to export petrochemicals, the provision of goods, services, and support for the maintenance or expansion of Iran's domestic production of petrochemicals is not within the scope of the sanctions relief provided.

On July 29, OFAC updated the SDN List to reflect reflagging or other changes to the identifying information for numerous vessels and shipping entities subject to secondary sanctions targeting Iran.

The United States did provide some (very limited) relief this quarter, with Secretary of State John Kerry in August extending by six months a waiver that allows satellite companies to provide Iranian state-run television to audiences abroad. Kerry initially waived the ban in February 2014 for a six-month trial period after Iran committed to stop satellite jamming. Also, Boeing announced on July 24 that it had entered into an agreement with Iran Air to sell aircraft spare parts under a licenses previously issued by OFAC; it is expected that this will lead to the first sale of products by a US aerospace company to Iran since 1979.

On September 23, OFAC addressed a frequently asked question regarding payments to Iranian civil authorities for overflights or emergency landing in Iran by aircraft that are owned by non-US persons and registered outside the United States. OFAC clarified that as long as the relevant transactions do not involve persons on the SDN List other than Government of Iran entities and depository institutions that have been designated solely pursuant to E.O. 13599, payments for the limited services referenced above are not subject to sanctions under US law. The involvement of other SDNs, including Iranian financial institutions designated pursuant to E.O. 13224 or E.O. 13382, would, however, create sanctions exposure for the participants in such transactions.

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