Iran Sanctions Prosecutions

29 Sep 2025 --
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Iran Sanctions Prosecutions: Overview

Background on Iran Sanctions

Sanctions against Iran are imposed primarily by the United States (through the Office of Foreign Assets Control or OFAC), the United Nations, and the European Union. The sanctions target Iran’s nuclear program, terrorism activities, and other national security concerns. They restrict trade, investment, and financial transactions with Iran or Iranian entities.

Key Legal Prohibitions

Prohibiting U.S. persons or entities from engaging in business with Iranian persons or companies.

Blocking Iranian assets or funds held in foreign jurisdictions.

Preventing export of technology, goods, or services to Iran, especially dual-use technologies.

Criminal penalties for knowingly violating sanctions laws, including fines, imprisonment, and asset forfeiture.

Notable Iran Sanctions Prosecutions and Cases

1. United States v. HSBC Bank USA (2012)

Facts: HSBC was accused of processing billions of dollars in transactions involving Iranian banks and entities, violating U.S. sanctions laws.

Legal Outcome: HSBC entered into a deferred prosecution agreement, agreeing to pay $1.9 billion in fines. The bank admitted to processing illicit transactions despite internal warnings.

Significance: This was a landmark enforcement action signaling strict penalties for financial institutions violating Iran sanctions, focusing on money laundering and sanctions evasion.

2. United States v. Reza Zarrab (2016)

Facts: Reza Zarrab, a Turkish-Iranian businessman, was charged with conspiring to evade U.S. sanctions on Iran by facilitating billions of dollars in gold-for-oil trades between Iranian entities and foreign banks.

Legal Outcome: Zarrab pleaded guilty and cooperated with prosecutors, exposing a wider network of sanctions evasion involving Turkish and Iranian officials.

Significance: This case exposed complex schemes used to circumvent sanctions, including fake trade transactions and using third-country intermediaries.

3. United States v. Huawei Technologies Co. Ltd. (2020)

Facts: While primarily a technology case, Huawei was charged with conspiracy to violate Iran sanctions by using a U.S. subsidiary to sell telecommunications equipment to Iran.

Legal Outcome: Huawei faced multiple charges, including sanctions violations. The case resulted in ongoing litigation and contributed to heightened scrutiny on tech exports to Iran.

Significance: Showed how multinational companies can be prosecuted for indirect violations of sanctions, especially through deceptive corporate structures.

4. United States v. Bijan Rafiekian and Kambiz Attar (2020)

Facts: Two former officials of the U.S. Department of Defense were charged with conspiracy to act as unregistered agents for the Iranian government and violating sanctions.

Legal Outcome: They faced criminal charges for attempting to influence U.S. policy in favor of Iran without proper disclosure and for engaging in illicit financial dealings.

Significance: This case illustrates the overlap between sanctions enforcement and counterintelligence efforts against covert influence operations linked to Iran.

5. United States v. Mariner Finance (2021)

Facts: Mariner Finance was charged with failing to implement adequate sanctions compliance programs, resulting in transactions that indirectly involved Iranian entities.

Legal Outcome: Mariner agreed to pay fines and adopt stricter compliance measures to resolve the matter without admitting wrongdoing.

Significance: Highlighted the importance of compliance and due diligence in preventing inadvertent violations of Iran sanctions, especially in financial services.