U.S. Treasury Department ("Treasury") Undersecretary for Terrorism and Financial Intelligence Sigal P. Mandelker addressed Iran's alleged "malign" activities and called on U.S. partners and allies to join efforts to confront Iran.
In remarks before the Foundation for the Defense of Democracies, Ms. Mandelker provided examples of Iranian misconduct in a range of areas, including (i) support for terrorism, (ii) undermining the international financial system and (iii) human rights violations. Ms. Mandelker also warned the non-U.S. business community to be wary of Iran's duplicity, and the frequent use of shell and front companies by sanctioned Iranian parties seeking to access international markets. Dealings with such entities could subject non-U.S. persons to U.S. sanctions, and Ms. Mandelker emphasized that U.S. authorities will "hold those doing business in Iran to account."
Commentary / James Treanor
Mandelker's comments underscore the Trump administration's intense focus on Iran's alleged misbehavior, which the U.S. government asserts extends well beyond the issue of nuclear proliferation. In particular, the speech reads like an indictment against the Central Bank of Iran, which has been implicated in a number of the activities cited by Mandelker (activities which have recently resulted in sanctions imposed on dozens of individuals and entities).
Her remarks will only fuel speculation that the Central Bank of Iran could itself be added to the Specially Designated Nationals and Blocked Persons list. Such a move would have significant ramifications, especially for non-U.S. financial institutions and others who could face potential secondary sanctions for continued dealings with the Iranian Central Bank.
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