U.S. Sanctions against the IRGC

 

The U.S. sanctions regime against the IRGC is expansively defined.  It includes not only entities or individuals designated by the [IRGC] tag in the Specially-Designated Nationals list, but also anyone who "facilitates, or participates or assists in, an activity..." that "facilitates a significant transaction or transactions or provides significant financial services" for the IRGC or its affiliates as designated with the [IRGC] tag.

 

Commercial organizations subject to primary and secondary sanctions under this program include:

 

  • Imensazan Consultant Engineers Institute
  • Gharargahe Sadandegi Ghaem
  • Omran Sahel
  • National Iranian Oil Company
  • Mehr Bank
  • Mehr-e Eqtesad-e Iranian Investment Company
  • Ghorb Karbala
  • Tehran Gostaresh Company
  • Rah Sahel Institute
  • Deep Offshore Technology Company
  • Fater Engineering Institute
  • Pouya Air
  • Rahab Institute
  • Sahel Consultant Engineers
  • Naftiran Intertrade Co. (NICO)
  • Tidewater Middle East Co.
  • Sepasad Engineering Company
  • Sepanir Oil and Gas Engineering Company
  • Khatam ol Anbia Construction Base
  • Makin Institute
  • Hara Company
  • Ghorb Nooh
  • Bonyad Taavon Sepah
  • Oriental Oil Kish
  • Iran Marine Industrial Company, SADRA
  • Syrian Arab Airlines

From Electronic Code of Federal Regulations, Title 31, Subtitle B, Chapter V, Part 561:

 

(5) Facilitates a significant transaction or transactions or provides significant financial services for—

(i) Iran's Islamic Revolutionary Guard Corps or any of its agents or affiliates whose property and interests in property are blocked pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (“IEEPA”); or

(ii) A person whose property and interests in property are blocked pursuant to parts 544 or 594 of this chapter in connection with Iran's proliferation of weapons of mass destruction or delivery systems for weapons of mass destruction or Iran's support for international terrorism; or

Note to paragraph (a)(5) of §561.201: The names of persons whose property and interests in property are blocked pursuant to IEEPA are published in the Federal Register and incorporated into the Office of Foreign Assets Control's Specially Designated Nationals and Blocked Persons List (the “SDN List”). The SDN List is accessible through the following page on the Office of Foreign Assets Control's Web site: www.treasury.gov/sdn. Additional information pertaining to the SDN List can be found in appendix A to this chapter. Agents or affiliates of Iran's Islamic Revolutionary Guard Corps (“IRGC”) whose property and interests in property are blocked pursuant to IEEPA are identified by a special reference to the “IRGC” at the end of their entries on the SDN List, in addition to the reference to the regulatory part of this chapter pursuant to which their property and interests in property are blocked. For example, an affiliate of the IRGC whose property and interests in property are blocked pursuant to the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 CFR part 544, will have the tags “[NPWMD][IRGC]” at the end of its entry on the SDN List. Persons whose property and interests in property are blocked pursuant to parts 544 or 594 of this chapter in connection with Iran's proliferation of weapons of mass destruction or delivery systems for weapons of mass destruction or Iran's support for international terrorism also are identified by the tag “[IFSR]” in addition to the tag referencing part 544 or part 594, as the case may be, located at the end of their entries on the SDN List (e.g., [NPWMD][IFSR] or [SDGT][IFSR]). In addition, see §561.405 concerning entities that may not be listed on the SDN List but whose property and interests in property are nevertheless blocked.

(6) Facilitates, or participates or assists in, an activity described in paragraphs (a)(1) through (a)(5) of this section, including by acting on behalf of, at the direction of, or as an intermediary for, or otherwise assisting, another person with respect to the activity.