However, that retaliation is unlikely to have much effect in terms of assets seizures or the interruption of transactions involving the Iranian financial system. Iranian officials have attempted to downplay the significance of some of the latest US sanctions by insisting that they have no assets outside of Iran, but this defense certainly applies to the FDD sanctions, in reverse. Since the Iranian economy is already highly isolated and the think tank does not directly operate inside the country, there are few if any opportunities for Iranian financial institutions to identify and confiscate assets belonging to it.

But this is not to say that the Iranian sanctions do not convey a meaningful threat, and the US State Department acknowledged as much when responding to the announcement. In a statement on Twitter, the department’s spokesperson Morgan Ortagus warned the “outlaw regime” of the US government’s intention to “hold Iran responsible for directly or indirectly compromising the safety of any American.”

The new Iranian measure names not only the FDD but also its CEO Mark Dubowitz, whom the regime accused of promoting the current US policy of “maximum pressure” and of spreading “lies, lobbyism, and propaganda against Iran.” Tehran’s announcement cited a 2017 law called “Countering America’s Human Rights Violations and Terrorist Actions,” which seemingly allows for a very broad interpretation of the regime’s legal tools for retaliating against perceived offenses by foreign entities.

Specifically, Iran’s Mehr News Agency stated that “any actions taken by the judicial and security apparatuses against the FDD and their Iranian and non-Iranian accomplices will be considered legitimate as their actions are against Iran’s national security and the interests of the Iranian People and government.” In this sense, the newly implemented measures on not limited to assets freezes within Iranian banks but also extend to crackdowns on affiliates and acquaintances of Dubowitz and the FDD, carried out by any of Iran’s security or paramilitary organizations.

The State Department’s response to the announcement is possibly indicative of concerns that Dubowitz may be made a particular target of terrorism by the Islamic Revolutionary Guard Corps or any of its various proxies, including Hezbollah. And although the US only formally repudiated “threats” against Dubowitz and other American citizens, the regime’s focus on the American think tank may also put activists and professionals inside the Islamic Republic at increased risk, within the context of a longstanding security crackdown.

As Iran Human Rights Monitor noted in a recent report, one of the latest features of that crackdown is an ongoing increase in the use of corporal punishment apart from the already highly overused death penalty. The Islamic Republic maintains the highest per-capita rate of executions in the world, but it is also one of the only nations that routinely sentences accused criminals to flogging, amputation, and dismemberment.

Just last week, IHRM reported that a teacher-activist named Mohammad Taghi Falahi had been sentenced to eight months in prison and 10 lashes, another teacher-activist named Hamidreza Rahmati had been sentenced to 18 months and 74 lashes, and a labor activist named Nasrin Javadi had been sentenced to seven years and 74 lashes for participating in Labor Day protests.

Previously, the same outlet reported that seven employees of the Haft Tapeh sugarcane plant had been sentenced to receive 30 lashes as punishment for their participation in a high-profile labor demonstration demanding improved conditions and payment of outstanding wages. Public knowledge of that protest and associated human rights issues grew in the wake of public statements by two other arrestees concerning the torture they had experienced and witnessed when detained last year for their involvement in the Haft Tapeh labor movement.

While these cases are not directly related to the new sanctions imposed on the FDD, they are representative of a trend that has also affected several American citizens, as well as untold numbers of Iranians who were subjected to additional scrutiny because of their ties to the West. At least five American citizens are currently in prison in Iran, and most have been sentenced to 10 year terms on the basis of unsubstantiated accusations of spying. With corporal punishment by the Iranian judiciary rising alongside tensions between Tehran and Washington, these individuals may be at risk of worse treatment than they have already received.

Activists with Western connections have already lost their lives as a result of the awful conditions and systematic mistreatment in Iranian prisons. In one prominent example from last year, the Iranian-Canadian academic and environmentalist Kavous Seyed-Emami was found dead in his prison cell shortly after being arrested alongside seven of his Iranian colleagues in the Persian Wildlife Heritage Foundation. The death was quickly ruled a suicide, but authorities blocked efforts at an independent autopsy in an apparent effort to conceal evidence of torture.

The Washington Post reported upon Seyed-Emami’s case once again on Monday, highlighting the implausibility of the spying allegations as well as the fact that four of his fellow detainees are now facing the possibility of capital punishment based on the vague, political charge of “spreading corruption on earth.” Four others could face up to 10 years in prison, and harsh sentences in Iran’s Revolutionary Court are historically very likely in cases where prosecutors are able to point to even fairly minor affiliations with Western organizations or high-profile individuals.

Tehran has a long track-record of punishing citizens for those associations, sometimes via criminal proceedings and sometimes by way of blanket-seizure of assets, or other semi-legal means. In 2017, the judiciary froze the domestic accounts of more than 150 employees and contributors of the British Broadcasting Corporation and barred them from all transactions within the country, as well as all foreign travel. The sanctions targeted the Foundation for Defense of Democracies seem to deliberately open the door for a repeat of this or any other enforcement measure, insofar as they preemptively justify “any action” directed against any affiliated person, whether a citizen of the Islamic Republic or any foreign adversary.