In Spite of Thaw, U.S. Imposes New Sanction on Those Involved in Iran’s Ballistic Missile Program

Within days after the lifting of nuclear weapons-related sanctions against Iran, President Obama announced new sanctions against Iranian and other entities involved in Iran’s ballistic missile program.  These sanctions, which were triggered by a recent missile test by Iran in violation of UN prohibitions, designated eleven Iranian, Chinese, and UAE entities and individuals who were determined to be involved in procurement activities on behalf of Iran’s ballistic missile program. These entities and individuals (list found here) have been added to the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals (SDN) List.

As a result, U.S. entities (and non-U.S. entities falling under U.S. jurisdiction), including financial institutions, may not engage in business with these individuals and entities, among other restrictions.  Non-U.S. entities outside U.S. jurisdiction who engage with these SDNs  risk exposure to U.S. secondary sanctions.

These new sanctions serve as an important reminder that despite the removal of certain nuclear weapons-related sanctions against Iran, serious tensions remain . Depending on Iran’s future behavior, including military activity outside of Iran, support for terrorist organizations, and any activity that backtracks on Iran’s commitments under the JCPOA, new non-nuclear related sanctions could be still imposed by the U.S. or EU.