United States, United Kingdom, and European Union Respond to Iran’s Attack on Israel

On April 13, 2024, Iran launched an attack on Israel. Following the attacks, the United States and United Kingdom imposed several sanctions targeting individuals and entities involved in Iran’s UAV and ballistic missile industries, steel industry and automobile industry. Additionally, the European Union announced it will take further restrictive measures against Iran, notably in relation to UAVs and missiles in response to the attack.

New US Sanctions:

On 18 April, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) designated 16 individuals and two entities enabling Iran’s UAV production. The sanctions targeted entities and individuals involved in the production of UAV engine types that power Iran’s Shahed variant UAVs used in the April 13^th attack. Further, OFAC designated five companies that were providing component materials for steel production or purchasing finished steel products from one of Iran’s largest steel producers that was designated in 2020. OFAC also designated three subsidiaries of an Iranian automaker that has continued to materially support to Islamic Revolutionary Guard Corps, Iran’s Ministry of Defense and Armed Forces Logistics, and other sanctioned entities. These actions are being taken pursuant to: E.O. 13382, a counterproliferation authority; E.O. 13871, which imposes sanctions with respect to the iron, steel, aluminum, and copper industries of Iran; and E.O. 13224, a counterterrorism authority.

As a result of OFAC’s designations, all property and interests in property of the persons 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, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.

For additional information concerning the individuals and entities designated in this action, please refer to the following notice.

New UK Sanctions:

On 18 April, the UK announced the addition of seven individuals and six entities to its Iran asset freeze list in response to the attack on Israel. These designations were made under the UK’s newly restructured Iran regime – the Iran (Sanctions) Regulations 2023 which came into force in December 2023. The new designations include military figures and companies involved in Iran’s unmanned aerial vehicle industry; the full list of designations can be found in HM Treasury’s notice.

Pending EU Sanctions:

On 18 April, the European Council announced that it will take further restrictive measures against Iran, notably in relation to UAVs and missiles in response to the Iranian attack against Israel.

During a summit held in Brussels on 17 and 18 April 2024, The European Council also strongly and unequivocally condemned the Iranian attack on Israel and reiterated its full solidarity with the people of Israel and commitment to Israel’s security and regional stability. The European Council called on Iran and its proxies to cease all attacks and urged all parties to exercise the utmost restraint and to refrain from any action that may increase tensions in the region.

The EU already has a wide range of measures in place which target Iran over its human rights abuses, nuclear proliferation activities and military support for Russia. The new measures in response to Iran’s attack on Israel have yet to be formally adopted by the Council of the EU.

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