Sanction Law
Your Guide to the Office of Foreign Assets Control

OFAC Goes Silent on Iran

In the lead-up to Iran’s elections on June 14, 2013, The United States Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) Office of Global Targeting (OGT) went into overdrive, issuing designation after designation. All told, in the month-and-a-half prior to the election OFAC issued six (6) designation actions compromising over 100 individuals, entities, aircraft, and vessels. However, in the seventy-six (76) days since the last designation on June 4, OFAC has been entirely mum on the Iran front, save two (2) congressionally mandated IFCA updates that did not add any additional names to the SDN list. To put that in perspective there has not been a comparably quiet period since mid-2010.

One explanation for the lack of designations could be that due to the frenetic pace set in May and early June, OGT used all the arrows in its quiver so to speak. Six (6) actions in a 45-day period is by far the most active the agency has been on Iran in recent memory, perhaps ever. Gathering the information and putting together the required designation packets is a time-consuming endeavor and it’s obvious that a decision was made to issue as many designations as possible prior to the elections.  It’s conceivable that this exhausted the supply of readily available designations and that we will soon begin to see the pace of new actions pick up.

Another possibility is that the Obama administration has deliberately halted designations in response to the election of Hassan Rouhani as opposed to a more extreme candidate such as former nuclear negotiator Saeed Jalili. Though a consummate regime insider, Rouhani positioned himself as a “moderate” or “centrist” during the campaign and few in either Iran or the West gave him much of a chance. Most analysts believed that given Supreme Leader Ayatollah Khamenei’s preference for a candidate more aligned with his worldview, he would select Jalili or former Tehran Mayor Mohammad Qalibaf as president, regardless of the actual ballot count.

With Rouhani assuming the presidency, there is hope that a deal over Iran’s disputed nuclear program may be possible and it’s not unthinkable that the White House told Treasury to lay off for now. According to a senior administration official quoted recently by Reuters, the Obama administration wants to give Rouhani a chance before any new sanctions are considered. While no new negotiations have been formally announced, Laura Rozen of Al-Monitor has reported that the P5+1 anticipates that that talks will resume sometime in September. The outcome of these meetings will likely determine when OFAC returns to the designation game.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or This post was co-authored by Samuel Cutler, Policy Advisor at Ferrari & Associates, P.C. He can be reached at 202-617-9122 or at

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