Trump Sanctions Iran

This heading is perhaps a bit more exciting than it should be, but maybe that’s necessary given the tone of the White House this week towards Iran, following that country’s recent missile tests.  Two days after US National Security Advisor Lt. Gen. (Ret) Michael Flynn announced that the administration was “officially putting Iran on notice,” the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) made a handful of designations of Iranian and other entities to its Specially Designated Nationals (SDN) list.

Today’s addition is relatively lengthy, with entities ranging from individuals in Iran to companies in the Persian Gulf and China.  They were designated under Executive Orders dating to the Bush Administration.  While this may sound exceptionally aggressive, it is relatively insignificant by many measures if viewed from a legal standpoint.  The Obama administration frequently made these types of designations.

The true impact of these designations is that they can potentially place a non-legal damper on Iran’s trade with the world.  While the SDN list is an “American” list – there are secondary sanctions, meaning that third country entities dealing with these entities could face some types of repercussions in their affairs in the United States.  Beyond that, all the designated entities are sure to be similarly blocked by other financial institutions and businesses around the world (for example, banks in Asia may also freeze their accounts or not do business with them).  This can naturally impact Iran’s access to missile technologies and related services.

More generally, the more negative press Iran receives and the more Iranian or Iran-related entities are designated on the SDN list.  It will raise the cost of due diligence, increase the number of potential flags. In the greater scheme of things, today’s designations may not be exceptionally significant and certainly more innocuous than any type of military response. It remains to be seen if any fundamental regulatory changes or new Executive Orders could be issued, both of which could have significantly more severe impact.

An international trade compliance (sanctions, export controls, customs, anti-corruption) and defense lawyer.

Posted in Uncategorized

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

Akrivis Law Group, PLLC
Washington, DC

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Join 109 other subscribers

This website aims to provide notes and commentary on international legal, business, and political developments in economic and other sanctions. It is intended solely for information and entertainment purposes and should in no way be construed as legal advice. Laws, regulations, and policies change from time to time so some information on older posts can very easily be dated. If you have any questions or are unclear on any of the subject matters addressed or discussed on this site, please consult a licensed legal professional. Views presented in the comments and outside links do not necessarily reflect those of the website author. All external links on this website to articles and documents are external and provided for informational purposes only. They have no relation to the author of this website unless specified otherwise.

This website is independent of Akrivis Law Group, PLLC and any statements of opinion posted on this website are therefore not to be considered positions of Akrivis Law Group, PLLC.

Quotations and linkages do not imply any type of endorsement.

Copyright 2023 Farhad R. Alavi.

All rights reserved.

US Sanctions Law Blog

%d bloggers like this: