https://www.powerlineblog.com/archives/2022/09/further-action-this-day.php

I noted in “The supremacy of Albania” that President Biden’s national security team had vowed to “take further action to hold Iran accountable for actions that threaten the security of a U.S. ally and set a troubling precedent for cyberspace.” The “troubling precedent” was Iran’s massive cyberattack on Albania government systems as spelled out in Prime Minister Rama’s statement.

Yesterday the United States Treasury announced what I take to be the administration’s “further action”:

[Treasury] is designating Iran’s Ministry of Intelligence and Security (MOIS) and its Minister of Intelligence [Esmail Khatib] for engaging in cyber-enabled activities against the United States and its allies. Since at least 2007, the MOIS and its cyber actor proxies have conducted malicious cyber operations targeting a range of government and private-sector organizations around the world and across various critical infrastructure sectors. In July 2022, cyber threat actors assessed to be sponsored by the Government of Iran and MOIS disrupted Albanian government computer systems, forcing the government to suspend online public services for its citizens.

The Treasury press release explains the consequences:

As a result of today’s designation, all property and interests in property of the designated targets that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Additionally, any entities that are owned 50 percent or more by one or more designated persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.

In addition, non-U.S. persons that engage in certain transactions with the persons designated today may themselves be exposed to designation. Furthermore, any foreign financial institution that knowingly conducts or facilitates a significant transaction for or on behalf of the persons designated today could be subject to U.S. correspondent or payable-through account sanctions.

In last night’s story on the sanctions, the Wall Street Journal drily reports: “Efforts to reach MOIS and Mr. Khatib weren’t successful.”

The highly targeted nature of the sanctions is problematic insofar as the Iranian regime is the source of the problem and is itself a criminal, terrorist, and genocidal operation.

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