International Law Advisory - Treasury Designates Iranian Individuals for Supporting the Proliferation of WMD

The Department of the Treasury, Office of Foreign Assets Control (OFAC), recently published in the Federal Register a notice designating two Iranian individuals under Executive Order 13382 (the EO). See 72 Fed. Reg. 126 at 36103-36104 (July 2, 2007).

 The EO authorizes sanctions against entities and individuals involved in the proliferation of weapons of mass destruction. It freezes any assets of the designees that are in the possession of U.S. persons or subject to U.S. jurisdiction and prohibits virtually all transactions between designees and any U.S. persons, including: (i) the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated entity or person; and (ii) the receipt of any contribution, funds, goods, services, etc. from designated entities or persons.

When EO designees include Iranian entities or individuals, as they do in the recent notice, the EO has the effect of adding a “blocking” provision to the Iranian Transactions Regulations (31 C.F.R. Part 560), which already impose comprehensive restrictions on U.S. companies and persons doing any business in or with Iran. This means that while the designations do not materially change the compliance posture for U.S. parties, they do require that if parties come into possession of property in which these designated entities have an interest, the acquisition of such property must be reported to OFAC, and the property generally cannot be dealt with further without specific OFAC authorization.  

The two individuals designated in today’s notice include:

1. QANNADI, MOHAMMAD (a.k.a. GHANNADI MARAGHEH, MOHAMMAD; a.k.a. GHANNADI, MOHAMMAD; a.k.a. QANNADI MARAGHEH, MOHAMMAD), c/o ATOMIC ENERGY ORGANIZATION OF IRAN, Iran; DOB 13 Oct 1952; POB Maragheh, Iran; citizen Iran; nationality Iran; Passport 20694 (Iran); alt. Passport A0003044 (Iran) (individual) [NPWMD]; and
2. LEILABADI, ALI HAJINIA (a.k.a. LAILABADI, ALI HADJINIA), c/o MESBAH ENERGY COMPANY, Iran; DOB 19 Feb 1950; POB Tabriz, Iran; citizen Iran; Nationality Iran; Passport E4710151 (Iran) issued 15 Oct 2000 expires 15 Oct 2005 (individual) [NPWMD]. 

We will continue to keep you apprised of sanctions and export control developments. If you have any questions regarding today’s notice or any related topic, please feel free to contact Ed Krauland at 202.429.8083.