COMMUNITY ADVISORY

2020 Iran Sanctions

As you may be aware, there have been sanctions imposed on Iran and Iranian businesses,
organizations, and individuals for decades. However, the former Trump Administration not only
imposed new sanctions by executive order, but it also significantly increased the number
individuals, entities and organizations which are subjected to sanctions, and included some of
Iran’s prominent religious universities, non-profit organizations, and masjid.

The sanctions are meant to be enforced against U.S. Citizens and Lawful Permanent Residents,
business who are operating inside of the United States, Banks Operating within the U.S., as well
as individuals who are located inside of the U.S. regardless of status.

This advisory contains a brief description of activities that are prohibited by the sanctions. This is
not intended to be an exhaustive list of subjects of the sanctions and does not constitute legal advice
of how to navigate the sanctions system. If you have specific questions about an activity,
organization, or situation, we strongly urge you to reach out to CAIR-MI directly.

PROHIBITED CONDUCT

Even though there are several Executive Orders dating back for several decades that are
implicated in Trump’s expansion of the Iran Sanctions below is a list of the conduct that is
prohibited in general:

1. The payment, exportation, withdrawal, or transfer of any property, or interest in property

held by the those who are subject to sanction.
2. The payment, exportation, withdraw, or transfer of any property, or interest in property
by any person (1) owned (2) controlled (3) acting on behalf of either directly or indirectly
(4) purported to have acted on behalf of either directly or indirectly any person or entity
sanctioned.
3. Making of donations, including money, food, medicine or clothing, by, to or for the
benefit of any sanctioned individual or entity.
4. Making contributions or provisions of funds, goods or services (1) by a sanctioned
person/ entity (2) to a sanctioned person/entity (3) for the benefit of a sanctioned entity.
5. Receiving contributions or provisions of funds, goods or services from a person/entity
sanctioned.
6. Providing goods and services
7. Providing material, financial, or technological support
8. Associating with the individual, entity, or organization that is sanctioned
9. Engaging in conduct that evades, attempts to evade, or conspires to evade the sanctions
 2020 AND 2021 ADDITIONS TO THE SANCTIONS LIST

While there were many additions to the sanctions list late in 2020 and early 2021, most notably
are the addition of the following entities and individuals, which includes prominent universities
and non-profit foundations. It is important to note that transactions involving entities that are
owned, controlled, or operated by any person or organization on the sanction list is also prohibited.
These prohibitions reach several prominent masjid which are often visited by U.S. Citizens and
Lawful Permanent Residents. As such, any engagement with these masjids must could bring about
scrutiny for sanctions violations.

• Islamic Revolution Mostazafan Foundation

• Bonyard Mostazafan and all owned or co-owned entities of Bonyad Mostazafan, Inc.
• Hasan Irlu, Al-Mustafa International University
• Yousef Ali Miraj
• Board Members of Bonyard Mostazafan
o Parvis Fattah,
o Amir-Mansour Borghei,
o Javad Ghana’at,
o Khosro Mokhtari, and
o Mohammad-Ali Yazdan Joo
• Iranian Bonyads
• Execution of Imam Khomeini’s Order (EIKO)
• Astan Quds Razavi (AQR)

ENFORCEMENT

Any U.S. person who violates the executive orders may be subject to civil penalties of up to the
greater of $250,000 or twice the transaction value, and criminal penalties for willful violations of
up to $1 million and 20 years in prison.

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