Shearman & Sterling LLP
Issue link: https://digital.shearman.com/i/1422677
6 IRAN This quarter saw limited Iran-related sanctions activity, presumably as the U.S. and others endeavor to resume diplomatic negotiations over the future of the Joint Comprehensive Plan of Action (JCPOA), which stalled in June. On September 3, OFAC took action pursuant to its human rights-related authorities to designate four Iranian intelligence operatives that allegedly targeted U.S. citizens and Iranian dissidents abroad as part of a campaign to silence critics of the Iranian government. According to OFAC, one of those designated, senior intelligence official Alireza Shahvaroghi Farahani, spearheaded a network that attempted to kidnap a U.S. journalist and human rights activist. As part of the broader campaign to target Iranian dissidents across the world, Farahani, Mahmoud Khazein, Kiya Sadeghi, and Omid Noori allegedly planned the abduction of a New York City-based Iranian-American activist by utilizing the services of a private investigator to conduct surveillance on the victim and laundered money from Iran to the United States to pay for the operation. The failed kidnapping plot led to the criminal indictment of members of Farahani's network in late July. All four individuals were designated pursuant to Executive Order 13553 for acting for or on behalf of Iran's Ministry of Intelligence and Security, which was itself designated in 2012 for human rights abuses against Iranians.