Late last week, Acting Under Secretary for Terrorism and Financial Intelligence (TFI)^[1]Adam Szubin appeared before the Senate Committee on Banking, Housing, And Urban Affairs. In his prepared statement to the Committee,  Mr. Szubin strongly implies that he will continue to focus on Iran.  This is a very significant statement of prioritization, as it comes from the highest ranking government official for both the enforcement of sanctions and money laundering controls. U.S. businesses with European partners that will re-enter the Iranian market should factor this continued enforcement focus into their risk-based approach to sanctions compliance.

Mr. Szubin’s statement and testimony follows the early September counterterrorism  designations of seven individuals and one entity for their links to Hamas, in addition to Samir Kuntar, a very prominent Hizballah member. (OFAC Recent Actions posting for the September 8, 2015 designations ; OFAC Press Release for the September 10, 2015 designations).  Interestingly, OFAC did not release a press release for the designation of Kuntar. As reported by the Jerusalem Post, upon release from Israeli authorities in 2008, Kuntar “thanked Teheran for its role in backing the Lebanese and Palestinian ‘resistance’ against Israel,” and stated that Iran “has played a crucial role in supporting the Lebanese and Palestinian resistance.”

We will continue to follow OFAC designations and provide insight into enforcement priorities as new developments arise.

[1] TFI is an office within the United States Treasury Department, which consists of the Office of Foreign Assets Control (OFAC), the Office of Intelligence and Analysis (OIA), the Office of Terrorist Financing and Financial Crime (TFFC), the Financial Crimes Enforcement Network (FinCEN), and the Treasury Executive Office for Asset Forfeiture (TEOAF).