The U.S. government announced yesterday that eight individuals were being added to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list.  These persons have been sanctioned due to their role in the perpetration of human rights violations in Iran following that country’s disputed 2009 Presidential election.

President Obama signed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) into effect on July 1. This law requires the President to periodically submit the names of individuals believed to have significant roles in human rights violations in Iran.

The named individuals are:

1. Mohammad Ali Jafari, Head of the Islamic Revolutionary Guards Corps (IRGC)
2. Saeed Mortazavi, Former Prosecutor General of Tehran
3. Sadegh Mahsouli, Iranian Minister of Welfare and Social Security (Former Minister of Interior)
4. Gholam Hossein Mohsen-Ejei, Prosecutor General of Iran (Former Minister of Intelligence)
5. Heydar Moslehi, Iranian Minister of Intelligence
6. Mostafa Mohammad Najjar, Iranian Minister of Interior (Former Minister of Defense)
7. Ahmad Reza Radan, Deputy Head of the Islamic Republic Police (NAJA)
8. Hossein Taeb, Deputy Head of the IRGC’s Intelligence Unit (Former Head of the Basij militia)

The sanctions require that any assets held by these individuals in the United States (or any that become subject to the jurisdiction of the US, including branches of U.S. companies abroad) be frozen.  Additionally, such individuals may face visa sanctions should they want to enter the United States.

Although it is unlikely that any of these individuals would seek to make private visits to the United States or to hold property therein, the significance of this Executive Order is that it could very well create difficulty for such individuals should they want to engage in business in third countries, as many third country entities employ screening methods before doing business with foreign nationals.  Furthermore, many other countries may follow suit and similarly sanction these individuals.