Larijani is already on the sanctions list in the European Union. The EU previously imposed sanctions on him when was accused of playing a key role in serious human rights violations. It has been reported that Mahmoud Hashemi Shahroudi, his predecessor as judiciary chief, may also be added to the EU sanctions list. While Shahroudi was in Germany for medical treatment, German authorities announced that he was under investigation for “crimes against humanity.” By January 12 he had returned to Tehran.

Morteza Razavi, president of Malaysia-based Green Wave Telecommunication and commercial director of Fanamoj, is now on the US list. October 2017 saw the company first appear on the US sanctions list. Active in telecommunications and satellite technology, Fanamoj has been accused of providing the Revolutionary Guards (IRGC) with parts for its missile program.

Also on the US list is Gholamreza Ziaei, who is the director of Rajaei Shahr Prison in Karaj near Tehran. Journalist Saeed Razavi Faghih talked an interview about the conditions in the prison, including “poor nutrition, unsanitary environment, lack of medical facilities and the ill-treatment of prisoners by the medical staff, unreasonable disciplinary measures, easy availability of illegal drugs, fights among prisoners that sometimes lead to serious injuries and even the deaths, and sexual abuse of some prisoners.”

The US government has cited the same issues. “Rajaei Shahr Prison has denied prisoners adequate medical care and access to legal representation,” says the US Treasury press release. “Many Iranians who recently protested against their government are imprisoned at Rajaei Shahr, a facility where prisoners participating in hunger strikes are denied medical care; where there are reported incidents of sexual abuse and unlawful executions; and where at least one prisoner had his eye gouged out by prison officials.” Hassan Akharian, head of Rajaei Shahr’s Ward 1, is already on the EU’s sanctions list.

The Supreme Council of Cyberspace is on the new list of US sanctions, as well. Supreme Leader Ayatollah Khamenei ordered its creation in 2012, to centralize and oversee the government’s policymaking and regulation of the internet. The council plays a facilitating role in blocking social networks and web content. When recent protests began, it was this body that ordered Telegram to be blocked. Members of this council include the president of the Islamic Republic, the speaker of parliament, the judiciary chief, the commander of the Revolutionary Guards, the commander of the national police, the president of Islamic Republic of Iran Broadcasting (IRIB), and seven members of the cabinet: the ministers for science, intelligence, education, defense, communications and technology, the Ministry for Islamic Culture and Guidance, and the Vice President for Science and Technology. President Rouhani is not on the sanctions list, but as head of the Supreme Council of Cyberspace his activities fall under the new US sanctions.

The National Cyberspace Center is also new to the US list. It is controlled by the Supreme Council of Cyberspace. Abolhasan Firoozabadi, the council’s secretary, is both the director of this center and the Deputy Labor Minister. The center has the task of drawing up a five-year plan for developing cyberspace, cyber surveillance and “anticipating cyber attacks and defending vital infrastructure against such attacks.”

The Islamic Revolutionary Guard Corps’ Electronic Warfare and Cyber Defense Organization has been added to the US list. Although it’s listed as a separate entity, the Revolutionary Guards’ various cyber units appear to be intertwined and it is not entirely clear which entities are exactly targeted by the new sanctions.

The US research firm Defense Tech reported in 2008 that the IRGC cyber army consisted of 2,400 full-time employees, and could leverage another 1,200 private hackers. Recent reports say that the IRGC is now using companies and individuals outside Iran to launch cyber attacks.

State-owned Iran Aircraft Industries (SAHA) has also been placed on the US sanctions list. The company was founded 51 years ago, but it was taken over by the Iranian Defense Ministry after the 1979 Islamic Revolution. SAHA provides key maintenance and overhaul services for Iran’s military helicopters and aircraft.

The Helicopter Support and Renewal Company (PANHA) is also on the US list. PANHA is a “leading Iranian helicopter maintenance and manufacturer, and has built and overhauled helicopters, including models manufactured in the United States, for the Iranian military and the IRGC,” according to the US Treasury.

Pardazan System Namad Arman (PASNA), known as PASNA Electronic, has, according to the US government, “sought to procure various types of lead zirconium tritanate (PZT) items valued at hundreds of thousands of dollars from China-based Bochuang Ceramic, Inc. on behalf of Iran’s ECI [Electronic Components Industries]. PZT items can transmit and receive electrical signals, and are used for anti-submarine warfare, torpedoes, mines, mine countermeasures, aircraft and ocean surveillance purposes.” This privately held company has been added to the US list.