Today, the Trump Administration imposed new sanctions on Iran for its testing last weekend of ballistic missiles. Last Sunday, On Sunday, Iran launched the Khorramshahr medium-range ballistic missile from a test site located approximately 140 miles east of Tehran, which traveled 600 miles before exploding. The missile test violated U.N. Resolution 2231 that was issued on July 20, 2015, which bars Iran from conducting ballistic missile tests for a period of eight years. This was Iran’s second missile test (the first one occurring in July 2016), and the first test made under the Trump Administration. 

Under the new sanctions, U.S. companies are now prohibited from dealing or engaging in transactions with 25 individuals and entities from China, Lebanon, the United Arab Emirates and Iran that are known to be: (1) involved in procuring technology or materials and supplying them to Iran in support of its ballistic missile program; and/or, (2) acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps. The 25 newly sanctioned individuals and entities were added to the Specially Designated Nationals List (SDN List) published by the Treasury Department’s Office of Foreign Assets Control (OFAC). 

The new sanctions targets include:

• Yahya Al-Hajj (Lebanon)

• Abdollah Asgharzadeh

• Tenny Darian 

• Hasan Dehghan Ebrahimi

• Muhammad ‘Abd-al-Amir Farhat (Lebanon)

• Mohammad Magham

• Kambiz Rostamian (UAE)

• Ali Sharifi 

• Qin Xianhua (China)

• Richard Yue 

• Mostafa Zahedi 

• Ghodrat Zargari

• Carol Zhou

• Cosailing Business Trading Company Limited (China)

• East Star Company 

• Ervin Danesh Aryan Company 

• Maher Trading and Construction Company (Lebanon)

• Mirage for Engineering and Trading (Lebanon) 

• Mirage for Waste Management and Environmental Services SARL (Lebanon)

• MKS International Co., Ltd. 

• Ningbo New Century Import and Export Company, Ltd. (China)

• Ofog Sabze Darya Company 

• Reem Pharmaceutical (Lebanon)

• Royal Pearl General T.R.D. (UAE)

• Zist Tajhiz Pooyesh Company 

The imposition of these new sanctions does not violate the nuclear deal with Iran (i.e., the Joint Comprehensive Plan of Action or “JCPOA”), in which the United States, Russia, China, France, the UK and Germany have agreed not to reimpose nuclear-related sanctions unless Iran’s breaches it nuclear program commitments. In this case, the new sanctions are being imposed as a result of Iran’s ballistic missile proliferation activities and sponsorship of international terrorism, and are authorized under various U.S. statutes (e.g., Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010; Iran Freedom and Counter-Proliferation Act of 2012; Iran Threat Reduction and Syria Human Rights Act of 2012; National Defense Authorization Act for Fiscal Year 2012; Iran Sanctions Act of 1996, etc.), the Iran Transactions and Sanctions Regulations (31 C.F.R. Part 560), and various Presidential Executive Orders. 

Again, U.S. persons are prohibited from dealing with individuals and entities on the SDN List, as well as with any entity that is owned or controlled by parties on the SDN List. Prohibited activities include imports, exports, reexports, transfers, sales, leases, purchases, financing, investments, transportation, insurance underwriting, guarantees, facilitation, etc. involving these parties. In view of these new sanctions, U.S. companies are urged to confirm that their restricted parties list screening processes and automated software applications are up-to-date so that potential dealings with these new individuals and entities are effectively blocked.