On April 27, 2023, the United States announced new sanctions on Iran for taking Americans and Iranian-Americans hostage. The Treasury Department specifically designated four senior officials in the Islamic Revolutionary Guard Corps (IRGC) Intelligence Organization (IRGC-IO), including:
Mohammad Kazemi, the IRGC-IO commander (see picture)
Mohamad Mehdi Sayyari, an IRGC-IO deputy chief
Brig. Gen. Mohammad Hasan Mohagheghi, an IRGC-IO deputy chief for counterespionage.
Ruhollah Bazghandi, an IRGC-IO official for counterintelligence.
Secretary of State Antony Blinken said that the actions were “a clear and direct warning to those around the world who wrongfully detain U.S. nationals of the potential consequences of their actions.” Iran’s practice of seizing and imprisoning foreign nationals, including dozens of Americans and dual Iranian-American nationals, has been a recurrent international issue since the 1979 revolution. Hostage-taking became a major tool of Tehran’s diplomacy and shadow warfare against adversaries.
Washington has repeatedly tried to win freedom for detained Americans and end the trend by trading arms for hostages in the 1980s; multiple rounds of behind-the-scenes diplomacy and layers of sanctions by at least four presidents; negotiations over a nuclear deal in 2015; unfreezing Iranian assets held by U.S. financial institutions in 2016; and swapping prisoners. But no tactic has sufficed to convince Tehran to abandon hostage-taking, which is widely recognized as a major violation of international law.
The announcement is not the first time that Washington has imposed economic sanctions on Iran’s most powerful military branch. In an unprecedented move, President Trump designated the entire IRGC in 2019. No other major military, including the Soviet Army at the height of the Cold War or the Nazi military in Germany during World War 2, had ever been sanctioned by Washington.
WRONGFUL DETENTIONS IN IRAN
Ruhollah Bazghandi is the IRGC-IO Counterintelligence official. In this role, Bazghandi has been involved with the detention of foreign prisoners held in Iran. Bazghandi has worked on behalf of the IRGC-IO in several capacities, including involvement in IRGC-IO’s operations in Syria, and assassination plots against journalists, Israeli citizens, and others deemed enemies of Iran.
Mohammad Kazemi became the commander of the IRGC-IO in June 2022. Kazemi oversees the IRGC-IO’s operations suppressing civil society in Iran and arresting Iranian dissidents, including dual nationals. He has also overseen the regime’s brutal crackdown against protests across the country in response to the killing of Mahsa Amini. Kazemi was previously designated by OFAC on October 26, 2022, for having acted for or on behalf of the IRGC.
Mohamad Mehdi Sayyari is the IRGC-IO Co-Deputy Chief. Sayyari has been directly involved in arranging logistics for prisoners in Iran.
Mohammad Hasan Mohagheghi, the IRGC-IO Co-Deputy Chief Brigadier General, has reported to several of the senior most IRGC Commanders on IRGC-IO operations. Mohagheghi served as a liaison between senior IRGC officials and IRGC-IO officials on counterespionage operations in Syria.
Ruhollah Bazghandi, Mohammad Kazemi, Mohammad Mehdi Sayyari, and Mohammad Hasan Mohagheghi are being designated pursuant to E.O. 14078 for acting or purporting to act for or on behalf of, directly or indirectly, the IRGC-IO, a person whose property and interests in property are blocked pursuant to E.O. 14078.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
Second publication by courtesy of The Iran Imprimer, Original-Text