Contempt for Rule of Law and Human Rights Incur OFAC’s Wrath - Association of Certified Sanctions Specialists

By David Williams, ACSS Editor
December 31, 2022

Iran has featured in the news for all the wrong reasons. It has borne witness to a cavalcade of human rights abuses that stretches back years, most arising from a clash in its theocratic rule and the will of many of its people, particularly the youth.

The Office of Foreign Assets Control (OFAC) announced on December 21 the sanctioning of Iran’s prosecutor general, key military and paramilitary officials, and a company manufacturing its law enforcement forces with anti-riot equipment.

OFAC summarized the developments leading to the decision, mentioning the nationwide protests and the escalating Iranian security force activities. It singled out the execution of two protestors, one publicly, and the death sentence of others.

“We denounce the Iranian regime’s intensifying use of violence against its own people who are advocating for their human rights,” said Brian Nelson, undersecretary of the Treasury for terrorism and financial intelligence. “The United States and our partners are dedicated to holding Iranian officials to account for egregious abuses committed against Iranian citizens fighting for their fundamental freedoms.”

OFAC’s decision follows Executive Order (EO) 13553, which authorizes sanctions when state officials and agents commit “serious human rights abuses.”

OFAC named Mohammad Jafar Montazeri (Montazeri), Iran’s prosecutor general, also referred to as the attorney general; Mohammad Kazemi, Islamic Revolutionary Guard Corps (IRGC) intelligence organization commander; Abbas Nilforushan, deputy commander for operations; and Iranian company Imen Sanat Zaman Fara.

Failure to Observe the Rule of Law

Montazeri oversees prosecutions and the enforcement of criminal judgments in Iran, including those brought in Iran’s Revolutionary Courts, where protestors were charged. Montazeri had directed courts to act “decisively” and firmly.

Paraphrasing “multiple international sources,” OFAC said the case of the first executed protestor, a young man named Mohsen Shekari, “proceeded with little resemblance to a meaningful trial.

“Mr Shekari was charged with blocking a street and attacking a security force member in Tehran who needed stitches. There is evidence that Mr Shekari was tortured and denied access to a lawyer. He was executed less than three weeks after his conviction.”

OFAC’s sources say defendants have been:

  1. Tortured by Iranian authorities to obtain confessions.
  2. Denied the right to be represented by counsel during trials before the Revolutionary Courts.
  3. Subject to “at least a dozen death sentences” by Iranian authorities in “sham Revolutionary Court trials.”
  4. Tried on capital charges for protesting, including minors.

Entity Designated for Assisting LEF

Imen Sanat Zaman Fara Company was designated for assisting Iran’s Law Enforcement Forces (LEF), specifically the special units, described by OFAC as one of Iran’s “main protest suppression forces.” The company produces armored vehicles for controlling crowds.

Treasury had already designated the LEF on June 9, 2011, for “its role in the 2009 post-election crackdown” and for supplying the LEF special units on December 7, 2021, both also pursuant to EO 13553.

OFAC said video and photographic evidence show Iranian security forces using Imen Sanat Zaman Fara’s armored vehicles to “suppress protests and attempt to run over protestors.” The company also produces automatic grenade launchers, bulletproof vests and shields.

Basij Resistance Forces Officials Designated

OFAC designated two senior officials of Iran’s Basij Resistance Forces, a paramilitary organization controlled by Iran’s Islamic Revolutionary Guard Corps (IRGC). OFAC said that Moslem Moein (Moein), as chief of the Basij Cyberspace Headquarters, “oversees efforts to control and censor Iranians’ online activities – he has spoken publicly about the Basij’s priority to monitor Iranians’ use of the internet.”

OFAC said Moein has advocated developing Iran’s national intranet, which could allow the regime to disconnect Iran from the global internet. The Iranian government continues to filter and block the free flow of information in Iran, OFAC said.

As the recently appointed deputy coordinator of the Basij, Hossein Maroufi (Maroufi) has played a role in the Basij’s violent response to the protests, said OFAC. It added that Maroufi was involved in the regime’s crackdown in 2019 during nationwide demonstrations stemming from a rise in gasoline prices.

In his role as the IRGC commander of Golestan province, Maroufi was allegedly responsible for ordering deadly weapons against Iranian protestors and orchestrating mass arrests of demonstrators, OFAC said.

Two IRGC Officials Designated

OFAC also targeted two IRGC officials, Hassan Hassanzadeh (Hassanzadeh), the commander of IRGC forces in Tehran, and Seyed Sadegh Hosseini (Hosseini), the commander of the Beit-al Moghadas Corps and IRGC commander in Kurdistan.

As commander of IRGC forces in Tehran, Hassanzadeh has “overseen the crackdown against protests in the city,” OFAC said. During the recent demonstrations in Tehran, OFAC said Hassanzadeh announced many protestors had been captured, claiming Basij members had been targeted and weapons confiscated.

OFAC said IRGC forces in Tehran allegedly arrested protestors to defend Iran’s centers of power.

In his role as the IRGC commander in Kurdistan, Hosseini has spoken out strongly against protestors in the region he oversees, OFAC said Hosseini was involved in the regime’s crackdown during the November 2019 protests shortly after he became the IRGC commander in Kurdistan and began serving on the provincial security council, OFAC said. It added that Hosseini authorized the use of deadly force against unarmed protestors and ordered the mass arrest of demonstrators, leading to the death of at least seven people.

Further Identification of the Designations

  • MONTAZERI, Mohammad Jafar (Arabic: محمد جعفر منتظری), Iran; DOB: Jan 21, 1949, to Feb 19, 1949; POB: Qom, Iran; nationality Iran; additional sanctions information: subject to secondary sanctions; attorney general of Iran; prosecutor general of Iran.
  • IMEN SANAT ZAMAN FARA COMPANY (Arabic: شرکت ایمن صنعت زمان فرا), Shahrak-e-Jafar Abad-e-Jangal Rd, Naseriyeh, Tehran, Iran; Number 16, Kolezar alley, Farsian Street, Shahid Rezaiee Street, Azadegan Autobahn, Tehran, Iran; Number 16, Gholshan 14, Golestan Boulevard, Negarestan Boulevard, Sham Abad, Tehran, Iran; additional sanctions information: subject to secondary sanctions; national ID no. 103201991293 (Iran); business registration number 369541.
  • MOEIN, Moslem (Arabic: مسلم معین) (aka MO’IN, Moslem), Part 7, Block 25, Ground Floor, 16th Street, Sarvestan Street, Chaghamirza Phase 2 Shahid Mehrabi, Kermanshah, Iran; Sep 22, 1985; POB Eslamabad, Iran; nationality Iran; additional sanctions information: subject to secondary sanctions; National ID No. 3341588477 (Iran); Birth Certificate Number 3477 (Iran).
  • MAROUFI, Hossein (Arabic: حسین معروفی) (a.k.a. MAROOFI, Hossein), Iran; DOB 1965 to 1966; POB Shahr-e Babak, Kerman province, Iran; nationality Iran; additional sanctions information: subject to secondary sanctions; deputy coordinator of the Basij.
  • HASSANZADEH, Hassan (a.k.a. HASSANZADEH, Hasan (Arabic: حسن حسنزاده)), Tehran, Iran; DOB Mar 21, 1957; nationality Iran; additional sanctions information: subject to secondary sanctions; IRGC brigadier general.
  • HOSSEINI, Seyed Sadegh (Arabic: سید صادق حسینی) (aka HOSSEINI, Sadegh), Kurdistan, Iran; DOB 1963 to 1964; POB Dehloran, Iran; nationality Iran; additional sanctions information: subject to secondary sanctions; IRGC Commander in Kurdistan.

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