FACTSHEET

IRAN SANCTIONS

UNITED STATES COMMISSION on

INTERNATIONAL RELIGIOUS FREEDOM

August 2020

One Decade On: Iranian Government Officials 

Sanctioned for Violating Religious Freedom

By Scott Weiner, Senior Policy Analyst and Dwight Bashir, Director of Outreach and Policy

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@USCIRF

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Gayle Manchin

Chair

Tony Perkins

Vice Chair

Anurima Bhargava

Vice Chair

Commissioners

Gary Bauer

James W. Carr

Frederick A. Davie

Nadine Maenza

Johnnie Moore

Nury Turkel

Erin D. Singshinsuk

Executive Director

USCIRF’s Mission

To advance international 

freedom of religion or 

belief, by independently 

assessing and unflinchingly 

confronting threats to this 

fundamental right.

Background

Since 1979, the Iranian government has systematically harassed, arrested, and executed 

members of religious minority communities. It has also used its interpretation of 

the Jaafari school of Shi’a Islam to severely violate the rights of nonbelievers, Shi’a 

Muslim dissidents, women, and members of the LGBTI community. For the past 

decade, the United States Commission on International Religious Freedom (USCIRF)

has recommended the use of targeted sanctions to hold senior members of Iran’s 

government accountable for these religious freedom violations.

On July 1, 2010, then-President Barack Obama signed into law the bipartisan

Comprehensive Iran Sanctions Accountability and Divestment Act (CISADA). 

USCIRF worked closely with congressional offices on these sanctions, which were the 

first to include provisions dealing with human rights and religious freedom violations. 

CISADA requires the President to submit to Congress a list of Iranian government 

officials, or persons acting on their behalf, responsible for human rights and religious 

freedom abuses, bar their entry into the United States, and freeze their assets. 

Pursuant to CISADA, President Obama issued Executive Order 13553 on September

29, 2010, imposing visa restrictions and asset freezes on eight Iranian officials for 

having committed serious human rights abuses after the disputed June 2009 elections,

six of whom USCIRF identified in May 2010 as severe religious freedom violators. 

Several other officials responsible for human rights and religious freedom abuses were 

subsequently sanctioned in 2011.

In August 2012, President Obama signed into law the Iran Threat Reduction and 

Syria Human Rights Act of 2012 (ITRSHRA), which enhanced the scope of human

rights-related sanctions contained in CISADA. Pursuant to ITRSHRA, the President 

issued Executive Order 13628 on November 12, 2012, imposing visa restrictions and

asset freezes on four officials and five entities. In December 2016, President Obama 

signed into law the bipartisan Global Magnitsky Human Rights Accountability Act,

which allows the U.S. government to impose sanctions and visa bans on any individual

responsible for committing gross violations of human rights worldwide. It also requires 

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USCIRF Legislation Factsheet: IRAN SANCTIONS: August 2020 2

the President to send to Congress an annual report on 

individuals sanctioned under the Act. 

The administration of President Donald Trump issued the 

first round of Magnitsky sanctions in December 2017. The 

administration has continued to use Global Magnitsky, 

CISADA, and related executive orders to sanction senior 

Iranian officials responsible for egregious violations 

of religious freedom. Additionally, on June 2, 2020, 

President Trump signed an executive order reiterating 

the importance of targeted sanctions under legal 

authorities, such as the Global Magnitsky Human Rights 

Accountability Act, as a response to egregious religious 

freedom violations in Iran and elsewhere, following 

a bipartisan precedent of imposing sanctions against 

these individuals. 

A detailed list of Iranian officials and entities 

sanctioned between 2010 and 2020 can be found at 

https://fas.org/sgp/crs/mideast/RS20871.pdf.

Available Measures to Impose Targeted 

Sanctions on Religious Freedom Violators

The following items represent the most relevant legislative 

provisions and executive orders under which the President 

has authority to impose religious freedom-related 

sanctions on Iranian officials and entities:

 CISADA Section 3 and Section 105

According to Section 3: “The President should

identify the officials of the Government of Iran and

other individuals who are responsible for continuing

and severe violations of human rights and religious

freedom” and prohibit these officials from entry into

the United States and freeze their U.S. assets. Section

105 targets individuals who are Iranian government

officials, or who are persons acting on behalf of the

Iranian government, and determined as responsible

for human rights abuses committed after the contested

June 2009 presidential election. The President is granted

full discretion to designate individuals, impose visa

restrictions, and block U.S.-based assets.

 Executive Order 13553

Executive Order 13553 authorizes the President

to target persons and entities that assist or provide

financial or material support to designated Iranian

individuals or entities.

 Executive Order 13606

Executive Order 13606 authorizes the President to

target computer and network disruption, monitoring,

and tracking by government authorities in Iran and

Syria. Sanctionable activities include the operation and

provision of technologies that facilitate computer and

network disruption, monitoring, or tracking, and that

could be used to commit serious human rights abuses

against Iranian citizens. When issuing the order in

2012, President Obama designated key entities such

as Iran’s Revolutionary Guard Corps, Ministry of

Intelligence and Security, and Law Enforcement Forces

(see Appendix 2). These entities will remain designated

and sanctioned.

 Executive Order 13628

Section 2 of Executive Order 13628 authorizes

the President to impose sanctions on any person

determined to have knowingly transferred or facilitated

the transfer of goods or technologies to Iran that are

likely to be used by the Iranian government to commit

serious human rights abuses against the Iranian people.

Moreover, Section 2 authorizes the President to impose

sanctions on any person who knowingly provided

services relating to hardware, software, or specialized

information or professional consulting, engineering,

or support services likely to be used to commit

serious human rights abuses in Iran. These entities

and officials will remain designated and sanctioned

(see Appendix 3).

 Executive Order 13846

Section 7 of Executive Order 13846 allows the U.S.

government to sanction entities that provide services

or transfer goods or technology to Iran that are likely to

be used by the government of Iran to commit serious

human rights abuses.

 Executive Order 13876

Executive Order 13876 allows the U.S. government to

freeze the assets of Iranian officials, including Supreme

Leader Ayatollah Ali Khamenei.
3 USCIRF Legislation Factsheet: IRAN SANCTIONS: August 2020

Most Recent Iranian Officials Sanctioned for Severe Religious Freedom Violations

Over the past year, the U.S. government has used several of these sanctions instruments to target senior Iranian officials 

responsible for severe religious freedom violations.

Mohammed Mohammedi Golpayegani

Mohammed Golpayegani is chief of staff 

in the Office of Supreme Leader Ayatollah 

Ali Khamenei. In 1991, Golpayegani 

issued a confidential memorandum to 

Khamenei outlining a plan for the 

systematic persecution of Baha’is in Iran, including 

expelling them from universities, destroying their cultural 

roots outside of the country, and denying them 

employment and positions of influence. He then 

collaborated with Ayatollah Khamenei to ensure the 

actualization of that plan. On November 4, 2019, the U.S. 

Department of Treasury designated Golpayegani under 

Executive Order (E.O.) 13876, which imposed sanctions 

on the Supreme Leader and his Office, representing the 

first time the Treasury Department has sanctioned an 

individual specifically for his role in orchestrating the 

persecution of Baha’is in Iran.

Mohammed Moghiseh

Mohammed Moghiseh presides over 

Branch 28 of the Tehran Revolutionary 

Court. He has routinely imposed harsh 

sentences against members of religious 

minority communities in Iran, including 

Christians, Sunni Muslims, and members of Iran’s Baha’i

community. In 2014, he sentenced eight Facebook users on 

charges of “blasphemy,” and in 2019, he sentenced lawyer 

Nasrin Sotoudeh to 33 years in prison—12 of which are 

enforceable under Iranian law—for defending women 

protesting the mandatory religious headscarf. On 

December 19, 2019, the U.S. Department of Treasury 

designated Moghiseh under E.O. 13846. USCIRF originally 

called for Moghiseh to be sanctioned in 2010 for severe 

religious freedom violations.

Abolghassem Salavati

Abolghassem Salavati presides over 

Branch 15 of the Tehran Revolutionary 

Court. He has regularly imposed 

extremely harsh sentences on members of 

religious minority communities, including 

former USCIRF Religious Prisoner of Conscience (RPOC) 

Mohammed Ali Taheri and members of the Baha’i, Sufi, and 

Zoroastrian communities. In 2014, a man who Salavati 

had convicted of “corruption on earth” and “heresy in 

religion” was executed at Rajai-Shahr prison. On 

December 19, 2019, the U.S. Department of Treasury 

designated Salavati under E.O. 13846. USCIRF originally 

called for Salavati to be sanctioned in 2010 for severe 

religious freedom violations.

Mohsen Reza’i 

Mohsen Reza’i is a senior member of Iran’s 

Expediency Council, a body which advises 

the Supreme Leader and can approve or 

amend laws received from Iran’s 

parliament. He served as commander of 

the Islamic revolutionary Guard Corps from 1981 to 1997. 

In 2006, an Argentinian judge issued an international 

arrest warrant through INTERPOL for Reza’i for his 

suspected role in the 1994 suicide bombing of the Jewish 

cultural center in Buenos Aires that killed 85 people—the 

deadliest terrorist attack in Argentina’s history. On January 

10, 2020, the U.S Department of Treasury designated Reza’i 

under E.O. 13876.

Ahmad Jannati

Ahmad Jannati is Chairman of Iran’s 

Guardian Council, which vets legislation 

and electoral candidates. He is also 

Chairman of the Assembly of Experts, 

which officially chooses Iran’s Supreme 

Leader. In 2005, Jannati claimed in a public speech that 

“Non-Muslims such as Zoroastrians, Christians, and Jews 

cannot be called human beings but are animals who roam 

the earth and engage in corruption.” Prior to the May 2017 

elections, Jannati declared—contrary to article 26 of Iran’s 

1996 council election law—that it was a violation of the 

Shari’a for non-Muslims to run as candidates in Shi’a 

Muslim-majority areas. In 2018, Jannati invalidated the 

election of a Zoroastrian politician to the Yazd city 

council. On February 20, 2020, the U.S. Department of 

Treasury sanctioned Jannati under E.O. 13876. USCIRF 

originally called for Jannati to be sanctioned in 2011 for 

severe religious freedom violations.
UNITED STATES COMMISSION on INTERNATIONAL RELIGIOUS FREEDOM

732 N. Capitol Street, NW, Suite #A714 

Washington, DC 20401 

202-523-3240 

www.USCIRF.gov

@USCIRF

Media@USCIRF.gov

Ayoub Soleimani

Ayoub Soleimani is Deputy Commander 

of Iran’s Law Enforcement Forces and 

oversees the country’s cyber police unit, 

which monitors social media and online 

political speech. Soleimani played a role in 

suppressing protests against the mandatory religious 

headscarf (hijab) in July 2019, calling an improperly worn 

hijab an “obvious crime.” Soleimani also called the 

removal of religious headscarves a “plot” devised by “the 

enemy” and said security forces would “confront it with no 

compromise”—an accusation that frames those with 

different religious beliefs as disloyal traitors. On May 20, 

2020, the U.S. Department of Treasury designated

Soleimani under E.O. 13553.

Conclusion

Over the past decade, two successive administrations have 

utilized newly passed legislation and executive orders to 

impose targeted sanctions on dozens of Iranian officials 

and entities responsible for egregious religious freedom 

violations in Iran. Although the Iranian government 

has continued to perpetrate severe religious freedom 

violations over the years, the ongoing documentation 

of specific abuses, and the identification of officials 

responsible, will significantly aid future efforts to hold 

them accountable. 

The U.S. Commission on International Religious Freedom (USCIRF) is an independent, bipartisan federal government entity established by the 

U.S. Congress to monitor, analyze, and report on threats to religious freedom abroad. USCIRF makes foreign policy recommendations to the President, 

the Secretary of State, and Congress intended to deter religious persecution and promote freedom of religion and belief.

Professional Staff

Danielle Ashbahian

Senior Communications Specialist

Keely Bakken

Policy Analyst

Dwight Bashir

Director of Outreach and Policy

Elizabeth K. Cassidy

Director of Research and Policy

Patrick Greenwalt

Researcher

Gabrielle Hasenstab

Communications Specialist

Roy Haskins

Director of Finance and Office 

Management

Thomas Kraemer

Senior Advisor for Strategic Outreach

Kirsten Lavery

Supervisory Policy Analyst

Jason Morton

Policy Analyst

Dominic Nardi

Supervisory Policy Analyst

Mohyeldin Omer

Policy Analyst

Jamie Staley

Senior Congressional Relations Specialist

Zack Udin

Researcher

Nina Ullom

Congressional Relations Specialist

Madeline Vellturo

Policy Analyst

Scott Weiner

Senior Policy Analyst

Kurt Werthmuller

Supervisory Policy Analyst