The U.S. Treasury announced on January 13, 2021, that it had designated Iranian venture firm Barkat Ventures for blocking sanctions. Treasury identified Barkat as a direct subsidiary of the Execution of Imam Khomeini’s Order (EIKO) and said the basis for the designation was EIKO’s direct or indirect ownership or control of the firm.
What Treasury announced about Barkat Ventures
Treasury’s January 13, 2021 announcement named Barkat Ventures among entities designated in an action involving EIKO, Astan Quds Razavi (AQR), their leaders, and subsidiaries. Treasury described Barkat as a direct EIKO subsidiary and a pillar of EIKO’s investments in cyberspace and information technology. Treasury’s announcement said Barkat was designated under Executive Order 13876 because it was owned or controlled, directly or indirectly, by EIKO.
This was distinct from EIKO’s earlier sanctions history. Treasury said EIKO had been identified as meeting the definition of the Government of Iran under Executive Order 13599 and added to OFAC’s Specially Designated Nationals and Blocked Persons List in 2013. The 2021 action against Barkat cited Executive Order 13876; the two orders and actions should not be conflated.
What the designation meant
Treasury’s release described the general consequences of blocking sanctions. Property and interests in property of designated persons must be blocked and reported to OFAC when they are in the United States or in the possession or control of U.S. persons. U.S. persons are generally prohibited from dealings involving property or interests in property of blocked or designated persons.
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Treasury also warned that people engaging in certain transactions with designated parties could themselves face sanctions, and that foreign financial institutions knowingly facilitating significant transactions or financial services could face correspondent-account sanctions. These are the release’s general descriptions; the treatment of a particular transaction depends on the applicable rules and circumstances.
What Treasury alleged about EIKO—and what it did not say about Barkat
Treasury described EIKO as directly supervised by Iran’s Supreme Leader, Ali Khamenei, and as a business with interests across major sectors of the Iranian economy. The department also said EIKO had systematically violated dissidents’ rights through property confiscations, including property belonging to political opponents, religious minorities, and Iranians living in exile. Those are allegations Treasury attributed to EIKO’s conduct and history.
As CyberScoop reported on January 13, 2021, Treasury made no specific allegation that Barkat itself carried out those confiscations; the stated basis for targeting the venture firm was its ownership or control relationship with EIKO. Treasury Secretary Steven T. Mnuchin’s statement that “these institutions enable Iran’s elite to sustain a corrupt system of ownership over large parts of Iran’s economy” referred to EIKO and AQR in the context of the broader action, not to a specific finding about Barkat.
What was reported about Barkat’s investment interests
CyberScoop’s contemporaneous report said Barkat’s apparent website listed interests including internet of things, electronic health, cryptocurrency, and software as a service. It also reported that the site described a goal of lowering barriers for entrepreneurs in “knowledge-based” businesses. These were claims reported from an apparent company website in January 2021, not independently verified holdings or a statement of Barkat’s current strategy.
The same report relayed the website’s claim of investments equivalent to more than $9 billion. That figure was not established as audited assets under management or as a verified portfolio value, so it should not be treated as a confirmed measure of Barkat’s investments.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Is Barkat Ventures currently on the U.S. sanctions list?
The cited sources establish that Treasury announced Barkat’s designation in 2021. They do not establish whether Barkat appears on OFAC’s current SDN List. Anyone assessing present-day compliance should consult OFAC’s current records and applicable sanctions guidance rather than rely on a historical announcement alone.
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