Many of the entities that the US has designated on proliferation grounds have been previously sanctioned under measures enacted by other authorities.
Canadian measures enacted in 2012, for example, had already targeted two composite material procurers that the US has just listed for involvement in Iran’s illicit missile and nuclear procurement networks. And EU sanctions were already in place against two quasi-governmental Iranian research outfits that the State Department on Friday said are involved in nuclear weapon-relevant research.
While Iran’s Foreign Ministry has called the new sanctions “negative and non-constructive”, they are not expected to substantially affect the current negotiations between Iran and the P5+1.
These updated designations highlight the need for compliance professionals to maintain awareness of all national and multinational sanctions regimes, not just those of the US.
The State Department measures are available here and the Treasury designations here.