Fight and Combat Rampant Iranian Missile Exports Act (2024 "National Security Supplemental" - Public Law No: 118-50)

Date issued: Apr. 24 2024

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TURBOFAC Commentary (273 words)

Notes:

1) This is one of a dozen or so sanctions related provisions of the 2024 "National Security Supplemental". The Fight and Combat Rampant Iranian Missile Exports Act (Fight CRIME Act) calls for the mandatory imposition of IEEPA-based blocking sanctions on any person affirmatively determined to have engaged in activities described at sections 5(a)(1)-(5), all of which is almost certainly sanctionable pursuant to at least one of the many other sanctions authorities targeting the Iranian military. One notable distinction, however, is section 5(a)(6), which contemplates the imposition of sanctions on a person that “is an adult family member of a person subject to sanctions for conduct described in [the substantive sanctions provisions]”.

2) One might expect OFAC to rarely, if ever, actually designate persons pursuant to this authority. With the exception of family members of sanctioned...