The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") sanctioned over two dozen individuals and entities for allegedly transferring over a billion dollars and euros to the Islamic Revolutionary Guard Corps ("IRGC") and Iran's Ministry of Defense and Armed Forces Logistics ("MODAFL"). The designated persons include a network of Iran-, United Arab Emirates- and Turkey-based front companies. Pursuant to Executive Order 13224, OFAC also designated MODAFL and an Iranian bank for their assistance to the IRGC-Qods Force.
As a result of OFAC's action, all property and interests in the property of these sanctioned entities and individuals that are in the United States or in the possession or control of U.S. individuals must be blocked and reported to OFAC. In addition, all dealings by U.S. individuals or within the United States that involve any property or interests in property of designated individuals are generally prohibited, and non-U.S. persons who engage in certain transactions with the designated individuals and entities may be exposed to sanctions or subject to an enforcement action.
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