ARTICLE
27 September 2019

OFAC Sanctions Iranian Entities For Providing Financial Support To Terrorist Network

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Cadwalader, Wickersham & Taft LLP

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OFAC designated the Central Bank of Iran ("CBI"), the National Development Fund of Iran ("NDF"), and an Iran-based company for providing funding mechanisms
United States International Law
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OFAC designated the Central Bank of Iran ("CBI"), the National Development Fund of Iran ("NDF"), and an Iran-based company for providing funding mechanisms that "the Iranian regime uses to support its terrorist network."

According to OFAC, CBI provided "billions" of dollars to the Islamic Revolutionary Guard Corps, its Qods Force and its terrorist proxy, Hizballah. OFAC stated that the NDF, which is Iran's sovereign wealth fund, has acted as a source for funding the Qods Force and Iran's Ministry of Defense and Armed Forces Logistics ("MODAFL"). OFAC also designated an Iran-based company, Etemad Tejarat Pars, for concealing financial transfers for MODAFL's military purchases, including funds from the NDF.

As a result of today's action, all property and interests in property of these entities, and of any entities that are owned, directly or indirectly, 50 percent or more by the sanctioned entities, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. OFAC regulations also generally forbid all dealings by U.S. persons, and all transactions that occur within or transiting the United States, that involve the property or interests in property of blocked individuals or entities. Non-U.S. persons, including foreign financial institutions, are advised that engaging in certain transactions with the entities targeted by this action may result in the imposition of sanctions.

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