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Trump Administration Re-Certifies Iranian Compliance with the Joint Comprehensive Plan of Action but Applies New Sanctions to Iranian Individuals and Entities

 

01 August 2017

​The Trump administration recently re-certified that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA, otherwise known as the “Iran Deal”), thereby extending the sanctions relief afforded to Iran pursuant to the landmark January 2016 accord until at least October 2017.  This is the second time that the Trump administration has taken this step, having previously certified compliance in May.  The administration is legally required to inform Congress as to the status of Iran’s compliance every 90 days.  The next such deadline will fall in October, by which point it is expected that a currently ongoing administration review of the JCPOA will be complete. 

In the meantime, the Office of Foreign Assets Control (OFAC) has added seven individuals and 11 entities on its list of Specially Designated Nationals (SDNs), thereby blocking their assets and prohibiting U.S. persons from dealing with them.  The U.S. State Department stated that the newly-sanctioned individuals and entities had provided support to Iran’s ballistic missile program, military procurement, or the Islamic Revolutionary Guard Corps, or functioned as a “transnational criminal organization.” 

The individuals added to OFAC’s SDN List include:

  • Mohammed Saeed Ajily (a.k.a. Sa’id Ajili – linked to Ajily Software Procurement Group)
  • Seyyed Reza Ghasemi (a.k.a. Seyed Reza Qasemi – linked to Rayan Roshd Afzar Company
  • Farshad Hakemzadeh – linked to Rayad Roshd Afzar Company)arshad Hakemzadeh – linked to Rayad Roshd Afzar Company)
  • Emily Liu (a.k.a. Emily Lau – linked to Shiraz Electronics Industries)
  • Mohsen Parsajam (a.k.a. Mohsen Kargar Hodjat Abadi, Mohsen Kargar Hodjatabadi, or Mohsen Kargar – linked to Rayad Roshd Afzar Company)
  • Mohammed Reza Rezakhah (a.k.a. Mohammad Reza Rezakhah – linked to Ajily Software Procurement Group)
  • Resit Tavan (a.k.a. Reshit Tavan – linked to Qeshm Madkandaloo Shipbuilding Cooperative Co.)

The entities added to OFAC’s SDN List include:

  • Abascience Tech Co. Ltd. (linked to Shiraz Electronics Industries and Emily Liu)
  • Ajily Software Procurement Group
  • Andisheh Vesal Middle East Company (linked to Ajily Software Procurement Group)
  • Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization (a.k.a. Islamic Revolutionary Guard Corps Aerospace Force Research and Self Sufficiency Jehad Organization or Islamic Revolutionary Guard Corps Aerospace Force Self-Sufficiency Jehad Organization)
  • Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jehad Organization (a.k.a. Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jihad Organization or Islamic Revolutionary Guard Corps Self-Sufficiency Jehad Organization)
  • Qeshm Madkandaloo Shipbuilding Cooperative Co. (a.k.a. Mad Kandalu Company, Mad Kandalu Shipbuilding Cooperative, Mad Kandalu Shipbuilding Cooperative Qeshm, or Madkandalou Company – linked to Islamic Revolutionary Guard Corps)
  • Ramor Group (a.k.a. Ramor Dis Ticaret Ve Insaat Yatirim Anonim Sirketi – linked to Resit Tavan)
  • Rayan Roshd Afzar Company (a.k.a. Rayan Roshd Company or Rayan Roshd – linked to Islamic Revolutionary Guard Corps)
  • Raybeam Optronics Co. Ltd. (linked to Emily Liu)
  • Raytronic Corporation, Limited (linked to Emily Liu)
  • Sunway Tech Co., Ltd. (linked to Shiraz Electronics Industries and Emily Liu)

If you have any questions or would like to discuss any of these matters further, please contact any of the authors listed on this page or your usual contact at Allen & Overy.  For more information on our global sanctions practice and team please click here.

 

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