NEW YORK — Here’s what happens when a business linked to Iran’s Islamic Revolutionary Guards Corps (I.R.G.C.) is targeted with sanctions. A representative of the Revolutionary Guards finds a lawyer in Dubai and says: “Look, I’m on this stupid U.S. Treasury list. I’ll give you 10 percent. Help me set up a shell company in Dubai or Malaysia.”
The Treasury Department enemy list (“Specially Designated Nationals”) is easy to find. It’s at www.ustreas.gov/offices/enforcement/ofac/sdn/. Revolutionary Guard tycoons in Tehran know that. Once they have a new shell company, say in a cousin’s name, they circumvent the list. They go on reaping the heady profits open to the in crowd when sanctions distort an economy.
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