Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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6 IRAN Continuing its recent trend, the US took limited actions against Iran this quarter, as the two countries continue indirect talks in Vienna to revive the multilateral Joint Comprehensive Plan of Action. Public reports suggest the negotiations may be developing in a positive direction. OFAC Targets Iran's Ballistic Missile Procurement Efforts On March 30, OFAC designated Iranian procurement agent Mohammad Ali Hosseini and two Iranian entities under his control, Jestar Sanat Delijan and Sayehban Sepehr Delijan, for their efforts to procure ballistic missile propellant-related components for Iran's missile program. Hosseini, who was designated for providing support to the Iranian Revolutionary Guards Corps Research and Self Sufficiency Jihad Organization ("IRGC RSSJO"), was reportedly involved in high level talks with IRGC RSSJO officials to procure processing machines for nitril butadiene rubber and an inert gas jet milling system from China using falsified shipping documents. These components are used in the production of solid missile propellant. OFAC designated Sina Composite Delijan Company, also alleged to play a role in this procurement network, for its support of the IRGC RSSJO. OFAC additionally sanctioned Tehran-based P.B. Sadr Co., which acted on behalf of sanctioned entity Parchin Chemical Industries ("PCI") to procure parts used to develop missile propellant. Specifically, P.B. Sadr Co. received centrifuge spare parts from China on PCI's behalf.

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