On April 29, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a new round of sanctions targeting a network of individuals and entities based in Iran and the People’s Republic of China (“PRC”), accusing them of facilitating the transfer of ballistic missile propellant materials to the Iranian Revolutionary Guard Corps (“IRGC”). This action is being taken in furtherance of the Trump Administration’s February 4, 2025, National Security Presidential Memorandum 2, which directs the U.S. government to curtail Iran’s ballistic missile program, to disrupt the IRGC, and to stop Iran’s support for Hezbollah, Hamas, the Houthis, the Taliban, al-Qa’ida, and other terrorist networks. The designations focus on actors linked to the procurement, development, and proliferation of missile technology, tightening restrictions on companies supplying dual-use goods and financial intermediaries facilitating these activities.

This latest action follows a series of recent sanctions aimed at Iran’s missile and defense sectors. Over the past several months, OFAC has announced multiple rounds of designations, signaling a continued effort by the U.S. to address concerns over Iran’s missile capabilities

The sanctions come at a time of renewed diplomatic engagement between Iran, the U.S., and European countries. Negotiations aimed at addressing Iran’s nuclear program are expected to resume this week, with Iran’s missile program reportedly remaining a key issue in the discussions. While Iran maintains that its missile development is not subject to negotiation, U.S. and European officials have expressed interest in including missile-related activities in the talks.

As negotiations unfold, the intersection of sanctions policy and diplomatic engagement will remain a critical dynamic. Whether these measures will incentivize compromise is a live question—one that policymakers and stakeholders will watch closely in the coming weeks.

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Jonathan Cross Yash Dattani Daniel Knaap