OFAC designates Ali Ansari, Smart Global Limited and three Iranian exchange houses
Sanctions-screening and correspondent-banking teams must block and report the newly designated Iranian financier, holding company, three exchange houses and front companies, and confine any Smart Global wind-down to General License Y
- — Bank and payments sanctions-screening teams must add all designated persons and entities — Ali Ansari; Smart Global Limited; Mohammad Darbani and Partners, Lavasani and Partners, and Mohsen Khandan and Partners General Partnership Companies; controlling partners Mohammad Darbani, Shokufeh Rostam Abadi, Zahra Sarshari, Ahmad Navai Lavasani, Amir Navai Lavasani, Mohsen Khandan and Ali Asghar Khandan; and front companies CDM Trading Limited and Naba Alzaki Raw Materials Trading LLC — to SDN name-and-identifier filters and block or reject any involved U.S. property or transactions, or risk OFAC enforcement on a strict-liability basis.
- — Screening teams must apply OFAC's 50 percent rule down the ownership chain — treating Smart Global Limited as blocked through Ansari's control and blocking any entity owned 50 percent or more, individually or in aggregate, by the designated persons even where not separately named — and account for the shell/front-company layering the designations describe.
- — U.S. persons with pre-existing exposure to Smart Global Limited must conduct any unwinding strictly within the scope and any time limit of General License Y, while U.S. correspondent-account operators and foreign banks' treasury and trade-finance teams must avoid knowingly facilitating significant transactions for the designated exchange houses or front companies, since foreign financial institutions doing so face secondary sanctions on their U.S. correspondent or payable-through accounts.
- — Bank and payments sanctions-screening teams
- — U.S. correspondent-account operators and U.S. persons with Smart Global Limited exposure (subject to General License Y)
- — Foreign bank treasury and trade-finance teams with Iran-nexus exposure
- — General License Y wind-down: U.S. persons relying on GL Y to unwind transactions involving Smart Global Limited must complete permitted activity within the license's authorized scope and any expiry it specifies; after that, no further dealings are authorized.