ARTICLE
24 November 2021

OFAC Sanctions Iranian Cyber Company And Associated Persons

CW
Cadwalader, Wickersham & Taft LLP

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OFAC designated an Iranian cyber company, along with six linked Iranian nationals.
United States New York International Law

OFAC designated an Iranian cyber company, along with six linked Iranian nationals. As a result, all property and interests in property of the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from transacting with them.

According to OFAC, the entity, along with a manager and five associated individuals, led a campaign attempting to influence the 2020 U.S. presidential election, and as such, they have been designated under Executive Order 13848 ("Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election"). OFAC stated that the cyber actors obtained or attempted to obtain U.S. voter information, intimidated voters via email, and engaged in disinformation campaigns between August and November of 2020.

The designations are part of a collective effort with the U.S. Department of State and the FBI, and are accompanied by an indictment of two of the designated individuals in the Southern District of New York. Both of these Iranian nationals were charged with (i) conspiracy to commit computer fraud and abuse, intimidate voters, and transmit interstate threats, (ii) voter intimidation, and (iii) transmission of interstate threats. One of the nationals was additionally charged with (i) unauthorized computer intrusion and (ii) computer fraud.

Primary Sources

  1. Treasury Press Release: Treasury Sanctions Iran Cyber Actors for Attempting to Influence the 2020 U.S. Presidential Election
  2. DOJ Press Release: Two Iranian Nationals Charged for Cyber-Enabled Disinformation and Threat Campaign Designed to Influence the 2020 U.S. Presidential Election

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