US Imposes New Sanctions on Iran

February 3, 2017

Treasury seal

On February 3, the U.S. Treasury announced new sanctions on 13 individuals and 12 entities for supporting Iran’s ballistic missile program and its Islamic Revolutionary Guard Corps (IRGC). “Iran’s continued support for terrorism and development of its ballistic missile program poses a threat to the region, to our partners worldwide, and to the United States,” said John E. Smith, acting director of the Office of Foreign Assets Control. The new sanctions come less than a week after Iran tested a medium-range ballistic missile. Washington condemned the launch and officially put Iran “on notice” on February 1. National Security Advisor Flynn added on February 3 that the “international community has been too tolerant of Iran’s bad behavior.” The following are statements from Flynn and the Treasury as well as a transcript of a briefing with senior administration officials on the sanctions.

 

Statement by National Security Advisor Michael T. Flynn on Iran

Feb. 3, 2017

FlynnToday, the United States sanctioned twenty-five individuals and entities that provide support to Iran’s ballistic missile program and to the Islamic Revolutionary Guard Corps’ Quds Force.

The Islamic Republic of Iran is the world’s leading state sponsor of terrorism and engages in and supports violent activities that destabilize the Middle East. This behavior seems continuous despite the very favorable deal given to Iran by the Obama Administration. These sanctions target these behaviors.

Iran’s senior leadership continues to threaten the United States and our allies. Since the Obama Administration agreed to the Joint Comprehensive Plan of Action with Iran in 2015, Iran’s belligerent and lawless behavior has only increased. Examples include the abduction of ten of our sailors and two patrol boats in January 2016, unwarranted harassment of vessel traffic and repeated weapons tests. Just this week, Iran tested a ballistic missile, and one of its proxy terrorist groups attacked a Saudi vessel in the Red Sea.

The international community has been too tolerant of Iran’s bad behavior. The ritual of convening a United Nations Security Council in an emergency meeting and issuing a strong statement is not enough.  The Trump Administration will no longer tolerate Iran’s provocations that threaten our interests.

The days of turning a blind eye to Iran’s hostile and belligerent actions toward the United States and the world community are over.

 

Action Targets 25 Involved in Iranian Destabilizing Activity

Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned multiple entities and individuals involved in procuring technology and/or materials to support Iran’s ballistic missile program, as well as for acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).

This action reflects the United States’ commitment to enforcing sanctions on Iran with respect to its ballistic missile program and destabilizing activities in the region and is fully consistent with the United States’ commitments under the Joint Comprehensive Plan of Action (JCPOA).  More specifically:

  • OFAC designated several networks and supporters of Iran’s ballistic missile procurement, including a critical Iranian procurement agent and eight individuals and entities in his Iran- and China-based network, an Iranian procurement company and its Gulf-based network, and five individuals and entities that are part of an Iran-based procurement network connected to Mabrooka Trading, which was designated on January 17, 2016.  This action was taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction and their means of delivery and supporters of such activity.
     
  • OFAC designated a key IRGC-QF-run support network working with Hizballah, including IRGC-QF official Hasan Deghan Ebrahimi, his associates Muhammad Abd-al-Amir Farhat and Yahya al-Hajj, and several affiliated companies in Lebanon.  This action was taken pursuant to E.O. 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.  The IRGC-QF was designated under E.O. 13224 on October 25, 2007 for its support to numerous terrorist groups.
     
  • OFAC designated Ali Sharifi, an individual providing procurement and other services on behalf of the IRGC-QF.  This action was taken pursuant to E.O. 13224.

“Iran’s continued support for terrorism and development of its ballistic missile program poses a threat to the region, to our partners worldwide, and to the United States.  Today’s action is part of Treasury’s ongoing efforts to counter Iranian malign activity abroad that is outside the scope of the JCPOA,” said Acting OFAC Director John E. Smith.  “We will continue to actively apply all available tools, including financial sanctions, to address this behavior.”

As a result of this action, all property and interests in property of those designated today subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

Abdollah Asgharzadeh Network

Abdollah Asgharzadeh is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Shahid Hemmat Industrial Group (SHIG). Asgharzadeh is an Iranian businessman who has been procuring controlled and dual-use technology and materials for over a decade to support Iran’s ballistic missile programs, primarily for SHIG.  He has previously worked to procure items on behalf of Aerospace Industries Organization (AIO).  AIO is the Iranian organization responsible for ballistic missile research, development, and production activities and organization, including SHIG and the Shahid Bakeri Industries Group (SBIG).  AIO, SHIG, and SBIG were identified in the Annex of E.O. 13382 in June 2005.

Tenny Darian is being designated for providing, or attempting to provide, support for, or services in support of, Asgharzadeh, and for acting, or purporting to act for or on behalf of, directly or indirectly, Asgharzadeh.  As an example of their procurement activities, Asgharzadeh and his associate Darian have sought to purchase and ship foreign-produced ball bearings, which are among the items required by SHIG to produce the Shahab-2 short range ballistic missile and Shahab-3 medium range ballistic missile.

Asgharzadeh and Darian have coordinated the procurement of dual-use and other goods for SHIG through intermediary companies that obfuscate that the goods are for SHIG and will support Iran’s ballistic missile program.

East Star Company and Ofog Sabze Darya Company are two such Iran-based companies used for shipments of dual-use and missile-related items to Iran.  East Star Company is being designated for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Asgharzadeh.  Ofog Sabze Darya Company is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Asgharzadeh and Darian.

Since 2013, Asgharzadeh has relied on a network of trusted China-based brokers and their companies to assist his procurement of dual-use and other goods for SHIG.  Asgharzadeh and Darian work with three China-based brokers – Richard Yue, a sales associate of Cosailing Business Trade Company; Jack Qin, an employee of Ningbo New Century Import and Export; and Carol Zhou – to import dual-use and other components and goods.

Yue is being designated for providing or attempting to provide financial or material support for Asgharzadeh. Cosailing Business Trading Company Limited is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Asgharzadeh.

Yue and Cosailing Business Trading Company purchase goods from other China-based suppliers on behalf of Asgharzadeh.  Yue and Cosailing Business Trading Company have both accepted financial compensation from Asgharzadeh and Darian in exchange for dual-use goods destined for Iran, including U.S.-origin goods.

Qin is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Asgharzadeh and Darian.

He is another China-based intermediary for Asgharzadeh and arranges transport to Iran of goods destined for Asgharzadeh’s customers, including SHIG, and accepts payment in return.  Qin uses Ningbo New Century Import and Export Company, Ltd. to facilitate shipments for Asgharzadeh to Iran.  Ningbo New Century Import and Export Company, Ltd. is being designated for providing or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Qin.

 Zhou is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Asgharzadeh and Darian.

Gulf-Based Rostamian Network

MKS International is being designated for providing financial, material, technological, or other support to AIO and SBIG.  Since 2011, MKS International has been involved in procuring controlled and other technology and materials to support Iran’s ballistic missile programs, primarily for AIO and SBIG.  MKS International utilized multiple front companies in order to circumvent export laws and sanctions.

Kambiz Rostamian is MKS International’s CEO and is being designated for acting for or on behalf of MKS International and Royal Pearl General Trading.  He has dealt directly with and received payments from AIO for the procurement of goods.  Rostamian has also acted as a direct intermediary to purchase parts through MKS.

Rostamian is also CEO of Royal Pearl General Trading, which is being designated for acting for or on behalf of MKS International.  Royal Pearl General Trading is a front company for MKS International that has worked with SBIG and AIO to procure components for Iran’s ballistic missile program.

Iran-based Network Working with Navid Composite and Mabrooka Trading

Ervin Danesh Aryan Company and Mostafa Zahedi

Ervin Danesh Aryan Company is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, Navid Composite.  Navid Composite was designated pursuant to E.O. 13382 in December 2013 as an Iran-based subsidiary of U.S.- and UN-designated Sanam Industrial Group, an entity designated in July 2006 pursuant to E.O. 13382 for its involvement in Iran’s ballistic missile program.  Ervin Danesh Aryan Company created previously-designated Mabrooka Trading to import sanctioned goods into Iran.  Mabrooka Trading was designated pursuant to E.O. 13382 in January 2016 for having provided, or attempted to provide, financial, material, technological, or other support to Navid Composite.

Ervin Danesh Aryan Company has contracted with Navid Composite since at least 2015 for the procurement of laboratory equipment.  Ervin Danesh Aryan Company facilitated the financial transactions, transportation and shipping costs, and post-sale servicing for these goods on behalf of Navid Composite.

Mostafa Zahedi is being designated for acting or purporting to act for or on behalf of, directly or indirectly, Ervin Danesh Aryan Company and Mabrooka Trading.  Zahedi, as an employee of Ervin Danesh Aryan Company, sought to acquire carbon fiber production equipment from foreign suppliers.

Zahedi also procured or attempted to procure via Mabrooka Trading carbon fiber-related production equipment from outside Iran on behalf of Navid Composite.

Zahedi and E.O. 13382-designated Hossein Pournaghshband, the Director of Mabrooka Trading, have procured for Mohammad Magham, the Managing Director of Navid Composite, and Navid Composite’s PAN-based carbon fiber production line since at least 2014.  Polyacrylonitrile (PAN) fibers are the chemical precursor of high-quality carbon fiber.  Carbon fiber, found in high-tech and common daily applications, is used in missiles and solid propellant rocket motors. Zahedi used Pournaghshband to procure goods from foreign suppliers ultimately destined for Magham.

Since as early as mid-2014, Zahedi, occasionally acting as an employee of Mabrooka Trading, procured PAN and carbon fiber equipment from foreign suppliers for Ervin Danesh Aryan Company, on behalf of Navid Composite. He also coordinated financial transactions between suppliers and Navid Composite for these goods. Zahedi’s procurement on behalf of Navid Composite was also in coordination with E.O. 13382-designated Chen Mingfu.

Mohammad Magham

Mohammad Magham is being designated for acting or purporting to act for or on behalf of, directly or indirectly, Navid Composite.

Since late 2014, Magham, Navid Composite’s Managing Director, worked with Zahedi and Mabrooka Trading to procure goods from foreign suppliers for use in Navid Composite’s carbon fiber production operations.

Navid Composite and Magham also contracted with other Iran-based companies in mid-2015 to supply PAN fiber.  The PAN fiber was for Navid Composite’s production facility in Rasht, Iran.  Magham also worked directly with E.O. 13382-designated AIO Director Mehrdad Akhlaghi Ketabachi to manage the financials of Navid Composite.  Ketabachi was designated in January 2016 pursuant to E.O. 13382 for acting or purporting to act for or on behalf of AIO.

Ghodrat Zargari and Zist Tajhiz Pooyesh Company

Ghodrat Zargari is being designated for providing, or attempting to provide, financial, material, technological, or other support for, or goods or services in support of, and for acting or purporting to act for or on behalf of, directly or indirectly, Mabrooka Trading.  Zist Tajhiz Pooyesh Company is being designated for providing, or attempting to provide, material, technological, or other support for, or goods or services in support of, Mabrooka Trading.

Ghodrat Zargari has served as the Iran-based technical sales advisor for Mabrooka Trading and senior technical and marketing manager of Iran-based Zist Tajhiz Pooyesh Company.  In this capacity, Zargari worked with Pournaghshband and Mabrooka Trading, as well as China-based broker and Mabrooka Trading associate Mingfu, to ship goods through China to Tehran, Iran.

Lebanon-Based IRGC-QF Network

Hasan Dehghan Ebrahimi, an IRGC-QF official based in Beirut, Lebanon who maintains direct ties to senior IRGC-QF officials in Tehran, is being designated for acting for or on behalf of the IRGC-QF.  Ebrahimi has facilitated cash transfers to Hizballah worth millions of dollars, including through U.S.-designated Hizballah construction firm Wa’ad Company.

Muhammad Abd-al-Amir Farhat and Yahya al-Hajj are employees of Ebrahimi and are being designated today for acting for or on his behalf.

Ebrahimi and his employees use a network of Lebanon-based companies with ties to the broader Middle East to transfer funds, launder money, and conduct business. Ebrahimi is the manager of Maher Trading and Construction Company, which has been used to launder funds and smuggle goods to Hizballah and is co-located with Wa’ad Company in Beirut.  Maher is being designated today for being owned or controlled by Ebrahimi.

Reem Pharmaceutical, Mirage for Engineering and Trading, and Mirage for Waste Management and Environmental Services are being designated today for being owned or controlled by Muhammad Abd-al-Amir Farhat.  Since 2011, Farhat has been the Chairman of the Board of Reem, a Lebanese pharmaceutical company that also does business in Iraq and Kuwait.  In addition, he is the general manager of Mirage for Engineering and Trading, a Lebanon-based construction company that also manages projects in Iraq worth millions of dollars. ince 1999, Farhat has also been the general manager of Mirage for Waste Management and Environmental Services, a Lebanese environmental services company specializing in the cleaning, collection, recovery, disposal, and treatment of waste.

Ali Sharifi

Ali Sharifi is being designated for acting for or on behalf of the IRGC-QF.  As of 2015, Sharifi worked to procure aviation spare parts on behalf of the IRGC-QF.  Sharifi has also worked to procure other sensitive items from sources in the Middle East and China on behalf of the IRGC-QF.

Click here for the detailed list. 

 

Senior Administration Officials

On an Announcement from the Treasury Department on Iran

 

February 3, 2017

Via Teleconference

SENIOR ADMINISTRATION OFFICIAL ONE:  As you’ve seen in the press release, today Treasury’s Office of Foreign Assets Control, which is commonly referred to as OFAC, designated 25 individuals and entities for their support to Iran’s ballistic missile program or for their support to the Iran – the Islamic Revolutionary Guard Corps Qods Force, which itself has been designated under Executive Order 13224 for providing material support to various terrorist groups, including Hizballah and Hamas.

Specifically, today OFAC designated three networks totaling 17 individuals and entities for their support to Iran’s ballistic missile program, including to the previously designated Aerospace Industries Organization and Shahid Hemmat Industrial Group, which are central players in Iran’s ballistic missile research, development, and production activities.  OFAC also designated a key Lebanon-based IRGC Qods Force support network comprised of seven individuals and entities working with Hizballah.  And finally, OFAC designated one individual for providing procurement and other services on behalf of the IRGC Qods Force.

As a result of this action, any property of these individuals and entities designated today that are subject to U.S. jurisdiction are blocked and U.S. persons are generally prohibited from engaging in transactions with them.  This means that financial transactions by U.S. persons are prohibited and exports to these individuals and entities are also prohibited, and consistent with statute, secondary sanctions attached to these individuals and entities.  And their names will appear on OFAC’s Specially Designated Nationals and Blocked Persons List, or SDN list. 

Secondary sanctions are those that are generally directed towards non-U.S. persons for specified conduct involving Iran that occurs outside of U.S. jurisdiction.  This means that non-U.S. persons who knowingly conduct or facilitate significant transactions with or who provide material or other – certain other support to these individuals and entities will themselves face being cut off from the United States. 

Broadly, these types of designations are critical to combating Iran’s malign activities that are outside the scope of the Joint Comprehensive Plan of Action, or JCPOA.  As we’ve said consistently, we will continue to counter Iran’s support for terrorism, its ballistic missile program, and other destabilizing activities, including through our sanctions.

And now I’d like to turn it back to our moderator.  Thank you.

MODERATOR:  Great, thank you very much.  Now I’d like to turn this over to our Senior Administration Official Number Two.

SENIOR ADMINISTRATION OFFICIAL TWO:  Thank you.  Let me say that Iran’s continued ballistic missile development and support for terrorism are very provocative and undermine security, prosperity, and stability throughout the region.  These designations today are our response to Iran’s ongoing ballistic missile program, including its ballistic missile test on January 29th, as well as its continued support for terrorism.  We have taken these actions today after careful consideration, and we will continue to respond with appropriate action, including through designating entities and individuals facilitating procurement for Iran’s ballistic missile program. 

Iran’s ballistic missile program continues to be of grave concern to the international community.  The January 29th ballistic missile test launch is inconsistent with UN Security Council Resolution 2231 and underscores the importance of continued international action to curtail such activity.  The United States is committed to the full implementation of Security Council Resolution 2231, which calls upon Iran not to undertake any launches of ballistic missiles designed to be capable of delivering a nuclear weapon and which expressly prohibits the transfer of missile technology control regime items and related support by any country to Iran’s ballistic missile program.

Additionally, in the past six months, Houthi forces trained and armed by Iran have attacked Emirati and Saudi vessels and threatened U.S. and allied vessels transiting the Red Sea, and they continue to threaten U.S. friends and allies in the region.  We have consistently said that we will continue to counter Iran’s support for terrorism, destabilizing activities in the region, human rights abuses, and its ballistic missile program, including through sanctions where appropriate.  It should not be of any surprise to Iran that we would take actions against companies and individuals that attempt to further Iran’s support for terrorism or aid its ballistic missile program.  These designations mark yet another step in our continued effort to aggressively target Iran’s ballistic missile program and terrorism-related activities.

Let me make clear:  These steps we have taken today are outside of the JCPOA.  The JCPOA is limited to Iran’s nuclear program, and the U.S. continues to implement its commitments under the JCPOA.  Iran’s provocative ballistic missile launches and other destabilizing activities in the region are a clear threat to regional security.  This is why we have acted today in designating these 25 individuals and entities. 

I want to reinforce the message that we will work positively with Iran when it abides by its international commitments, while underscoring our commitment to aggressively counter Iran’s destabilizing activities, including its support for terrorist and militant groups. 

Thank you.  Let me turn it back to the moderator.

MODERATOR:  Thank you very much.  Now I’m turning this over to our Senior Administration Official Number Three.  Go ahead, [Senior Administration Official Three].

SENIOR ADMINISTRATION OFFICIAL THREE:  I think that the statements that have already been prepared and delivered address the challenges that we face with Iran, and I would stress that these are just initial steps in response to Iranians’ provocative behavior, and that we’ve been going through a deliberative process.  We are just finishing our second week and we’re still putting our team members in place across the agency.  But I would stress that we have gone through a normal process here where we had our coordinating committee, with input from the whole interagency, validation of these targets developed by Treasury, and we continued to deliberate.  And we made our recommendations through a normal process considering risk as well as advantages in providing those recommendations to the Deputies Committee, which convened and agreed with the recommendations and these actions that were taken today.  That’s all I have to say at this point.

MODERATOR:  Great.  Thank you very much to our senior administration officials.  Jon, Operator, if you can open up for our first question.

OPERATOR:  And just a quick reminder, ladies and gentlemen, if you have a question, please press *1.  And first go to the line of Matthew Lee with the Associated Press.  Please go ahead.

QUESTION:  Thanks.  I’m sorry, I kept hitting *1 because I wasn’t hearing any beep.  Anyway, my question is a simple logistical one.  I just want to make – double check that there are no sanctioned entities today that are re-designated from the list – from the entities that were dropped after the JCPOA.

SENIOR ADMINISTRATION OFFICIAL ONE:  Matthew, this is [Senior Administration Official One].  I want to confirm that that’s right.  There are no re-designations of previously designated persons in today’s action.

MODERATOR:  Thank you very much.  Operator, if we could move to our second caller.

OPERATOR:  We’ll go to Andrea Mitchell with NBC.  Please go ahead.

QUESTION:  Thank you very much.  Can – Senior Official Number Three, can you tell us more about that deliberative process?  At what stage, if at all, was there an NSC or a decision by the President?  Was it done at the deputies level, at the principals level – just to explain in this, as  you’re all gearing up and I know you’re staffing, how this worked?  Thank you.

SENIOR ADMINISTRATION OFFICIAL THREE:  It was a very normal process, worked through the National Security Council and the interagency.  The recommendations and decisions were forwarded up as per our directive that guides all of our deliberations for informing and getting approval from the President.  I would refer you to that document that was published earlier this week.

MODERATOR:  Thank you.  Moving to caller number three.

OPERATOR:  We’ll go to Margaret Brennan with CBS News.  Please go ahead.

QUESTION:  Thanks.  I just want to clarify that none of these sanctions today would impact some of the deals, like the Boeing deal, that has been in the works post nuclear agreement.  And if we can clarify from a policy perspective, does the U.S. – does the Administration view a tax by groups allied with Iran as the same thing as a tax by Iran?  Specifically, the mention of Houthi forces being trained and armed, does the Administration believe that they are under the command and control of Iran?  Thanks.

SENIOR ADMINISTRATION OFFICIAL ONE:  This is [Senior Administration Official One].  I’ll take the response to the first question, Margaret, which is – the question was clarifying that none of the sanctions impacts such things as the Boeing deal, et cetera.  And I’ll just frame it as, as everyone has stated, these actions – these – the designations taken today were to combat action – activity outside the JCPOA.  So things like the Boeing deal, et cetera, are not directly affected by today’s actions.

MODERATOR:  Great.  Would some – go ahead, please.

SENIOR ADMINISTRATION OFFICIAL THREE:  As to the relationship of Iran, for example, to the Houthis and how we connect the dots, first of all, I would say that we are very concerned about the freedom of navigation in the Bab-el-Mandeb area, and that is an important consideration because it does impact global commerce.

Number two, Iran has heavy influence, continues to arm and support the Houthis.  Iran is responsible for the access to arms, not necessarily responsible for every tactical decision.  What we will say, though, is that Iran in its relationships with proxies throughout the region bears responsibility for these groups that they are closely entwined with, and we examine each case individually to develop the information required to make appropriate and deliberate decisions.

MODERATOR:  Thank you.  If we can move to our next question.

OPERATOR:  We’ll go to Carol Morello with The Washington Post.  Please go ahead.

QUESTION:  Hello.  Thank you.  Senior Administration Official Number Three said these are just initial steps in response to Iran’s behavior.  I was wondering if you have anything in mind that may be imminent, and what exactly would be – might Iran do that would provoke your moving to this next step?

SENIOR ADMINISTRATION OFFICIAL THREE:  Iran has a continuing operation throughout the region, continues to conduct and support through its own forces, like the IRGC and Qods Force, as well as its proxies, behavior that is not sustainable, not acceptable, and violates norms and creates instability in the region.  Iran has to determine its response to our actions.  Iran has a choice to make.  We are going to continue to respond to their behavior in an ongoing way at an appropriate level to continue to pressure them to change their behavior.

MODERATOR:  Thank you.  If we can move to our next question.

OPERATOR:  We’ll go to Michelle Kosinski with CNN.  Please go ahead.

QUESTION:  Hi.  Thank you.  Can you tell me what kind of exposure do you think these people and entities have to the types of dealing that you’re prohibiting?  Are there any assets, is there any transaction that you know of with American entities already?  Because it seems like the effect overall might be quite small, but maybe you can shed some light on that.

And secondly, you said that the missile launch was inconsistent with the UN resolution, and that’s similar language that we’ve heard from the State Department, but it’s different from the language that comes from the White House saying that it is specifically in violation of that resolution.  So could you also add some clarity there?  Thanks a lot.

SENIOR ADMINISTRATION OFFICIAL ONE:  Hi, Michelle.  This is [Senior Administration Official One].  I will take the response to the first question alone regarding any impact of these individuals and entities.  Though they are located overseas, we assess them to have touchpoints to the United States with leverage over U.S. jurisdiction.  For example, they procure U.S.-origin goods, or they may have transactions that hit the U.S. financial system, and that would be blocked by this action.

SENIOR ADMINISTRATION OFFICIAL TWO:  Maybe I can address the second part of the question.  I mean, certainly we have said that these missile launches now and in the past are in defiance of 2231.  I don’t recollect an administration official using the term “violation” per se, but the Security Council resolution is very clear.  Iran – the Security Council calls upon Iran not to undertake ballistic missile tests.  These tests are extraordinarily provocative and they’re extremely destabilizing.  Additionally, the Security Council resolution makes clear that Iran can’t undertake these activities when a ballistic missile would be capable of carrying a nuclear weapon, and in this case, this kind of ballistic missile meets that very qualification.  Those are ballistic missiles that can travel a certain distance and carry a certain payload, and this ballistic missile falls within that parameter.

MODERATOR:  We can move to our next question, please.

OPERATOR:  And we’ll go to Yeganeh Torbati with Reuters.  Please, go ahead.

QUESTION:  Hi, thanks for doing this.  This is maybe more for [Senior Administration Official One].  Can you make clear – a lot – some of these sanctions were linked to a network, the Mabrooka Group that was sanctioned last year during the Obama Administration.  Did the work in terms of identifying these individuals and entities and teeing them up for possible sanctions, did that start during the Obama Administration?

SENIOR ADMINISTRATION OFFICIAL ONE:  Thanks, June.  I would just note that we would – we have consistently been following up and researching targets that go beyond the – Iran’s activities settled in the JCPOA that go beyond the nuclear file.  So we have been consistently focusing targeting efforts on Iran’s ballistic missile program, its support for terrorism, et cetera.

MODERATOR:  Thank you.  We have time for two more questions.  Jon, if we could go to the next one.

OPERATOR:  And that will be David Clark with AFP.  Please, go ahead.

QUESTION:  Hi, good morning.  Thanks for doing this.  The question is slightly a follow-on from Yeganeh’s, as it happened.  The ballistic missile test was on January 29th, as you said, which is only four days ago.  And obviously, this is a very detailed list.  Would these sanctions have been going into place at some point if the ballistic missile test hadn’t happened?  Hello?

SENIOR ADMINISTRATION OFFICIAL THREE:  The determination to make this decision on these sanctions was made in a process and a review.  We are undertaking a larger strategic review.  The launch of the missile was the triggering event. 

MODERATOR:  Thank you.  That was Senior Administration Official Number Three.   And we’ll move to our final question.

OPERATOR:  That will be Carol Giacomo with The New York Times.  Please, go ahead.

QUESTION:  Hi, this has got three parts to it.  Somebody mentioned that you were still willing to work positively with Iran.  How do you see yourselves working positively with Iran?  Have you reached out to Iran at all?  Have there been any contacts with Iran since this Administration took over?  Have you spoken to the allies about this action and your actions going forward in terms of Iran?

And one other thing:  Do you consider the Houthis to be a terrorist group?

SENIOR ADMINISTRATION OFFICIAL THREE:   The United States maintains constructive dialogue with our allies.  We do coordinate.  We did do this with the parties that we needed to.  We will not comment on our communications with Iran.  Thank you.