Jeremy Paner Discusses Sanctions Risks for Companies Providing Services to IRGC-Linked Entities with Fox News
Analyzes a Chinese tech company's risk exposure arising from apparent services to the Persian Gulf Straits Authority.
Highlights
A Chinese certificate authority’s issuance of digital security credentials to Iran's sanctioned Persian Gulf Straits Authority raises U.S. sanctions concerns.
Even routine or automated services provided to sanctioned Iranian entities creates sanctions risk exposure for non-Iranian companies.
Ongoing remediation and enhancements to sanctions compliance programs remain critical when identifying potential exposure to IRGC-linked entities.
Jeremy Paner spoke with Fox News about the U.S. sanctions risk exposure for companies providing services involving Iran's Islamic Revolutionary Guard Corps (IRGC).
Discussing the scope of U.S. sanctions designation authorities, Paner emphasized that even routine, automated services can expose non-Iranian companies to sanctions risk.
“The U.S. has incredibly broad authority to impose sanctions on non-Iranian companies that provide any sorts of services to sanctioned Iranian companies,” Paner said. “Many times, that authority will be abbreviated or explained as being providers of material support to sanctioned Iranian companies. But in fact, any level of services whatsoever could be the basis for the United States imposing sanctions against the company for providing services to Iran.”
Paner also explained why the issuance of digital security credentials to a sanctioned Iranian entity could create sanctions exposure, regardless of whether the service was provided through an automated process.
“Restoration of the certificate is unequivocally sanctionable,” he said. “Restoring the certificate is/was a service provided to the PGSA, which can be the basis for imposing sanctions pursuant to Executive Order 13224, as amended. That authority does not in any way require that the service be 'knowingly' provided to the PGSA [Persian Gulf Straits Authority].”
Paner highlighted the discovery of the potentially sanctionable services as a chance for the company to remediate its Iran exposure and compliance protocols.
“OFAC would expect TrustAsia to use the discovery as an opportunity to enhance its compliance program before it is too late,” he said. “Iran's attempt to extort the world in the movement of oil through the Strait of Hormuz is of the utmost importance to OFAC, which is the agency that implements and enforces U.S. economic sanctions.”
Paner also addressed the broader risks associated with doing business with IRGC-linked entities.
“There's always reputational risk involved in any company that decides to do business with the IRGC,” Paner said. “If I were advising TrustAsia, I would at minimum immediately identify all other IRGC companies receiving services.”
Featured Lawyers
Stay Up to Date
Sign up to receive practical updates, fresh perspectives and helpful guidance delivered straight to your inbox.
Stay connected for our latest news and insights.