The Department of the Treasury Office of Foreign Assets Control ("OFAC") imposed sanctions on the Governor and a senior official of the Central Bank of Iran, and on an Iraqi bank (al-Bilad Islamic Bank) and its Chairman, for allegedly funneling millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force ("IRGC-QF") to Hizballah. They were also listed as Specially Designated Global Terrorists ("SDGTs") pursuant to Executive Order 13224 ("Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism"). This action, in conjunction with OFAC's action last week, seeks to "stifle Iran's ability to abuse the U.S. and regional financial systems."

Sanctions on certain transactions with the Central Bank of Iran will be reimposed as of August 7, 2018, pursuant to President Donald J. Trump's decision to cease participation by the U.S. government in the Joint Comprehensive Plan of Action (see previous coverage). On November 5, 2018, additional sanctions will be reimposed on persons who knowingly engage in certain significant transactions with the Central Bank of Iran.

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