On February 3, 2017, in response to recent Iranian ballistic missile tests, the U.S. Office of Foreign Assets Control (OFAC) added 13 individuals and 12 entities to the Specially Designated Nationals and Blocked Persons (SDN) list. The additions, which include individuals and entities in Iran, United Arab Emirates, Lebanon, and China, were made pursuant to two existing executive orders that address weapons of mass destruction proliferation and counterterrorism (EO 13382 and EO 13224). Accordingly, these new additions to the SDN list are consistent with U.S. commitments under the Joint Comprehensive Plan of Action (JCPOA), and no new nuclear-related sanctions or secondary sanctions have been imposed or reimposed. The press release describing the actions taken by OFAC can be found here.

While there have not been any changes to the existing regulations or sanctions programs, this latest U.S. action is noteworthy for two reasons. First, it serves as a reminder that there are still sanctions related to Iran, in particular, non-nuclear secondary sanctions that can be applied to non-U.S. persons trading with certain Iranian individuals and entities.¹ In addition, this appears to be an uptick in the posturing between the United States and Iran and an initial demonstration of the harder line stance the Trump administration has vowed to take toward Iran.

Companies engaged in trade with Iran should continue to exercise caution, especially with the Trump administration suggesting a desire to revisit the JCPOA. We will continue to monitor the situation and release updates as further actions occur.

¹ U.S. persons (including U.S. citizens and permanent residents, entities organized under U.S. law, and any person in the United States) remain broadly prohibited from transactions involving Iran unless authorized by OFAC.