533. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?
On August 2, 2017, the President signed into law the "Countering America’s Adversaries Through Sanctions Act" (Public Law 115-44) (CAATSA), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global terrorism Executive Order 13224 on Iran’s Islamic Revolutionary Guard Corps (IRGC) and foreign persons that are officials, agents, or affiliates of the IRGC. Consistent with that requirement of CAATSA, OFAC designated the IRGC on October 13, 2017, pursuant to E.O. 13224 for providing support to the IRGC-Qods Force, which previously had been designated for its support to various terrorist groups. In addition, effective October 31, 2017, OFAC amended the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, to block the property and interests in property of foreign persons that have been identified by OFAC as officials, agents, or affiliates of the IRGC. [10/30/2017]
1) See 594.201(a)(5), providing for the blocking of "Foreign persons that are identified on the Specially Designated Nationals and Blocked Persons List (SDN List) maintained by the Office of Foreign Assets Control as officials, agents, or affiliates of Iran's Islamic Revolutionary Guard Corps (IRGC)."
It appears that the GTSR needed amending because there was no specific provision for the blocking of "affiliates" or "agents" of an SDGT.
2) This FAQ was issued prior to the designation of the IRGC as an FTO.