On February 3, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned more than two dozen individuals and entities related to Iran’s ballistic missile program and the Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF).  The move comes amid escalating tensions between the Trump Administration and the Iranian government.

The new sanctions were triggered by Tehran’s ballistic missile test on January 29, 2017.  The sanctions target 25 individuals and entities, including Chinese firms suspected of supporting Iran’s missile program.  These entities and individuals include MKS International Co., Ltd., East Star Company, and Ofog Sabze Darya Company, as well as three China-based brokers involved in the procurement of dual-use technology and materials for Iran’s ballistic missile program.  The sanctions also target IRGC-QF’s Lebanon-based network working with Hezbollah, including Maher Trading and Construction Company, Reem Pharmaceutical, Mirage for Engineering and Trading, and Mirage for Waste Management and Environmental Services.  The property and interests in property of the designated individuals and entities are now blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

According to Administration officials, this action was taken outside the scope of the Joint Comprehensive Plan of Action (JCPOA), which was finalized in 2015 and is intended to restrict Iran’s nuclear activities in exchange for easing international sanctions against the country.  The JCPOA, and the earlier easing of the Iranian sanctions, remain in place.  However, the Trump Administration has indicated that the U.S. government is reviewing its overall policy towards Iran, suggesting that further changes to the sanctions regime could be forthcoming.