1. It is critical that U.S. and non-U.S. companies comply with U.S. sanctions to avoid exposure to sanctions or an enforcement action under U.S. law. U.S. persons, including U.S. companies, continue to be broadly prohibited from engaging in transactions or dealing with Iran and the Government of Iran unless such activities are exempt from regulation or have been authorized by the Department of the Treasury’s Office of Foreign Assets Control (OFAC).
    1. The Islamic Revolutionary Guard Corps (IRGC) has been designated pursuant to Executive Orders 13224, 13382, 13553, and 13606 and accordingly is listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List). This means that the IRGC’s property and interests in property are blocked within the United States when such property or interests in property comes within the possession or control of any U.S. person, and U.S. persons generally are prohibited from transacting with it. In addition, the SDN List includes a number of other blocked IRGC affiliates.
    2. The IRGC exerts control over a vast swath of Iran’s economy through an extensive network of front companies and the Bonyad Taavon Basij.
    3. Due to a lack of market transparency, it may be difficult or impossible for the international business community to ensure that transactions involving Iran are not assisting the IRGC’s malign activities or benefiting corrupt IRGC and regime leaders.
  2. The United States does not tell foreign companies what to do, however, we can choose not to conduct business with those that do business with our adversaries. If a foreign company chooses to engage in sanctionable activity involving Iran, it risks exposure to U.S. sanctions, including sanctions that would effectively sever its ties with the U.S. market. U.S. companies could face enforcement action for engaging in prohibited conduct involving Iran.
  3. The re-imposition of U.S. sanctions that were lifted or waived in connection with the Joint Comprehensive Plan of Action is only the beginning of the most aggressive sanctions campaign in history. Maximum pressure means maximum pressure.

U.S. Department of State

The Lessons of 1989: Freedom and Our Future