More Executive Action Against Iran

Due to timing, it is assumed rather than a U.S. military strike campaign against designated targets as a result of Iran shooting down a U.S. drone, Cyber Command initiated a cyber operation. The Iranian Revolutionary Guard maintains control of the rocket and missile systems and they have been disabled as the U.S. response. Iran has confirmed the cyber-attack but also says it failed. Iran expected a response by the United States and in advance shut down several radar sites.

The United States has been inside several cyber operations in Iran for a very long time and was ready for a go order. Meanwhile, The US Cybersecurity and Infrastructure Security Agency (CISA) is warning that Iran has been advancing their own cyber operations against select US targets. It is unclear what those targets are.

President Trump spent the weekend at Camp David while Secretary of State Mike Pompeo traveled to Saudi Arabia and to Abu Dhabi while NSC John Bolton is in Israel. Bolton has on his calendar meetings with the Israeli national security and atomic energy officials as the introduction of the coming peace plan proposal dealing with the Palestinians will be introduced in Bahrain.

Photo: Alex Brandon AP

Trump has signed yet another addition to the sanctions architecture on Iran. There is talk of sanctions relief if Iran is willing to negotiate on key topics including escalating uranium enrichment. So far, Iran has said they will not meet with the United States and will shoot down other aircraft if they impede Iran airspace. The FAA has ordered all U.S. commercial aircraft to reroute outside of the existing Iran airspace buffer zone.

There are now heavy decisions for Europe to make in their economic trade with Iran versus that of the United States and remaining in the JCPOA, the Obama nuclear deal with Iran.

The Executive Order signed by President Trump goes right to the top of the regime yet does not yet include Mohammad Javad Zarif, the top Iran diplomat, however it is said that could come later in the week.

The new round of sanctions is all about existing monies controlled by the IRGC and the Iran Supreme leader and his associates. This includes access to revenues from oil exports and freezes the financial assets of key officials where the Iran Central Bank is listed.

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Additional Executive Order sanctions details:

Today’s action targets commanders of the IRGC’s Navy, Aerospace, and Ground Forces, in addition to the commanders of the IRGC Navy’s (IRGCN) five naval districts. These include the naval district commanders who are responsible for the IRGCN’s activities off the coast of the southern provinces of Khuzestan, Bushehr, and Hormozgan, which lie adjacent to the Persian Gulf and the Strait of Hormuz.

OFAC is designating IRGCN Commander Ali Reza Tangsiri pursuant to E.O. 13224 for acting for or on behalf of the IRGC. As recently as February 2019, Tangsiri threatened that the Iranian regime’s forces would close the Strait of Hormuz, an international waterway, if U.S. sanctions stopped Iran’s oil exports, and that the Iranian regime is prepared to target U.S. interests in the region. As the commander of the IRGCN, Tangsiri sits atop a structure—including those regional IRGCN commanders sanctioned today—that is responsible for the sabotage of vessels in the international waters.

Also designated today pursuant to E.O. 13224 for acting for or on behalf of the IRGC is Amirali Hajizadeh, commander of the IRGC Aerospace Force, whose bureaucracy was responsible for downing the U.S. unmanned aircraft on June 20, 2019. Hajizadeh oversees Iran’s provocative ballistic missile program.

OFAC is also designating pursuant to E.O. 13224 Mohammad Pakpour, commander of the IRGC’s Ground Forces, for acting for or on behalf of the IRGC. Under Pakpour’s command, the IRGC Ground Forces have deployed to fight in Syria in support of the IRGC-Qods Force (IRGC-QF) and the brutal Assad regime. In 2017, Pakpour said that the IRGC Ground Forces were in Syria to help the IRGC-QF.

OFAC is also designating the commanders of the IRGCN’s five naval districts pursuant to E.O. 13224 for acting for or on behalf of the IRGC. The IRGC is responsible for the Regime’s destabilizing and provocative naval actions in and around the Strait of Hormuz.
IRGCN commanders of five naval districts designated today are:

IRGCN 1st Naval District Commander Abbas Gholamshahi
IRGCN 2nd Naval District Commander Ramezan Zirahi
IRGCN 3rd Naval District Commander Yadollah Badin
IRGCN 4th Naval District Commander Mansur Ravankar
IRGCN 5th Naval District Commander Ali Ozma’i

The IRGC was designated pursuant to E.O. 13224 by OFAC on October 13, 2017 and it was designated as a Foreign Terrorist Organization by the Secretary of State on April 15, 2019.

Sanctions Implications

As a result of today’s action, all property and interests in property of these individuals that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.

In addition, persons that engage in certain transactions with the persons designated today may themselves be exposed to designation. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals designated today could be subject to U.S. correspondent account or payable-through sanctions.