How State Department Coordinates Sanctions in Response to Protest Crackdowns

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On January 15, 2026, the Treasury Department announced sanctions against 18 Iranian officials and entities for their role in one of the deadliest protest crackdowns in modern Middle Eastern history. The press release named names: Ali Larijani, the Secretary of Iran’s Supreme Council for National Security. Provincial military commanders including those in Ilam Province and other regions where documented abuses occurred. A prison where women had been tortured. And—perhaps most tellingly—eighteen shadow banking entities that had moved billions of dollars through falsified invoices and shell companies across multiple countries.

This is how the State Department coordinates sanctions when governments massacre their own citizens: through daily coordination meetings between Treasury and State officials, intelligence assessments compiled while Iran’s internet was completely dark, diplomatic calls at odd hours to European capitals, and legal review that determined which individuals could be sanctioned without getting the designations thrown out in court.

Executive Orders as Policy Tools

The authority to sanction Iranian officials for human rights abuses traces back to September 2010, when the Obama administration issued Executive Order 13553 in response to Iran’s brutal suppression of the 2009 Green Movement protests. That executive order gave the Treasury Secretary broad power to add anyone involved in “serious human rights abuses by the Government of Iran.”

Broad power matters here. State Department officials don’t need to prove beyond reasonable doubt that a specific commander personally pulled a trigger. They need “good reason to think someone did it”—a much lower bar that reflects the practical reality of sanctioning officials in authoritarian states that actively suppress information about their security operations.

The January 2026 designations used multiple executive orders to justify the sanctions. Executive Order 13876 provided authority to target Ali Larijani because of his direct advisory role to Supreme Leader Ali Khamenei. Executive Order 13902, which targets Iran’s financial and petroleum sectors, covered the shadow banking networks. Using multiple legal authorities makes it harder for courts to overturn the decision.

But executive orders can’t force behavioral change if the people being sanctioned don’t care about frozen assets or travel bans. A provincial military commander whose wealth sits in Tehran real estate and whose loyalty to the regime matters more than international banking access won’t stop killing protesters because the U.S. froze accounts he doesn’t have.

The First 48 Hours: When Information Goes Dark

On January 8, 2026, as protests intensified across Iran, the regime shut down the entire internet. Not selective blocking of social media platforms. Not throttling speeds. A complete nationwide blackout that would last more than 170 hours.

For State Department officials trying to document human rights abuses in real-time, this created an immediate crisis. The standard process for building sanctions cases relies heavily on open-source information: social media posts showing security force violence, news reports with witness testimony, videos uploaded by protesters. When Iran cut the internet, all of that stopped.

The State Department’s human rights office typically coordinates with organizations like Human Rights Watch and Amnesty International, which maintain networks of researchers and activists on the ground. Those networks went silent. Iranian activists who normally smuggled information out through encrypted messaging apps had no way to connect. International journalists in Tehran couldn’t file reports or verify casualty figures.

The coordination process adapted. Intelligence agencies shifted to other collection methods—satellite imagery, intercepted military communications, and information from people using Starlink satellite internet connections that bypassed government controls. Officials relied more heavily on pre-blackout documentation and on public statements from the regime. When a provincial governor appeared on television defending security force actions in his region, that showed his role in the crackdown.

Inter-Agency Coordination: Treasury, State, and Intelligence

The formal coordination between State and Treasury operates through channels refined over years of Iran sanctions. Career Foreign Service officers in State’s Iran sanctions team meet regularly with Treasury officials who specialize in Iran designations. During the January crisis, those regular meetings became daily, sometimes twice daily.

The intelligence community—CIA, Defense Intelligence Agency, signals intelligence agencies—provided classified assessments that added to what was publicly available. This intelligence includes details unavailable to the public: intercepts of communications between commanders, satellite imagery showing security force deployments, information from sources inside Iran’s government. The intelligence doesn’t need to be evidence strong enough to prove guilt in court. It needs to give policymakers confidence that the people they’re designating did what they’re accused of doing.

Treasury’s financial enforcement office handles the actual work: maintaining the list of people and companies the U.S. is freezing assets for, processing designations, and ensuring U.S. banks actually freeze the money. When this office adds someone to the list, U.S. banks must freeze any assets that person holds and reject any transactions involving them.

The decision to designate specific individuals moves up through multiple levels of review. Working-level officials identify potential targets and compile evidence. Assistant secretaries check that the legal case is solid and fits with broader U.S. strategy. Deputy secretaries ensure the sanctions align with broader U.S. goals. The Secretary of State and Secretary of the Treasury sign off before public announcement.

These multiple levels of review create places where officials can pause and ask if the evidence is solid or whether the sanctions affect negotiations with European allies. During the January 2026 crisis, this process operated under faster schedules. What normally takes weeks happened in days. The White House, responding to President Trump’s public statements about possible military action, wanted concrete measures announced quickly. State and Treasury officials tried to keep evidence standards high while moving fast.

International Coordination: Making Sanctions Multilateral

Sanctions work better when multiple countries do them together. An Iranian official who can’t access U.S. banks but can still use European financial institutions has lost some options but retained others. An official who can’t access U.S. or European banks has a much bigger problem.

The G7 joint statement on January 15 reflected weeks of diplomatic engagement through multilateral and bilateral channels. State Department officials in the Europe Bureau and the Office of the Special Envoy to the Middle East held secure video conferences with foreign ministers from European capitals. They shared intelligence details—enough to justify the sanctions without revealing sources. They coordinated timing so that announcements would come in close proximity, showing that the international community was acting together.

The European Union’s process requires consensus among all 27 member states to implement sanctions. One objection blocks the entire package. State Department officials spent considerable time lobbying hesitant EU members, emphasizing the precedential importance of coordinated action and presenting sanctions as human rights measures rather than power plays.

European Commission President Ursula von der Leyen said the EU wanted stronger sanctions to force regime change. This went further than U.S. officials would typically go publicly. American statements focused on accountability for specific abuses rather than regime change. But the State Department didn’t object—stronger European language helped justify the U.S. position while allowing American officials to maintain a narrower focus on human rights violations.

Human Rights Organizations: Documentation Partners

When Treasury announced that security forces in Lorestan Province had “shot multiple civilians, including one whose deceased body was held by security forces to coerce the family into falsely identifying the individual as a martyr for the government,” that specific detail came from human rights organizations that had documented the incident through witness interviews and family testimony.

Organizations like Human Rights Watch, Amnesty International, and the Washington, D.C.-based Human Rights Activists News Agency (HRANA)—which operates through an extensive network of volunteers inside Iran to document abuses—work alongside the government on sanctions. The State Department relies on these reports both for specific factual details and for corroboration of intelligence assessments.

HRANA’s death toll estimate of at least 2,403 confirmed deaths as of January 14, 2026, appeared in State Department statements and press releases. This was deliberate—it showed the evidence came from sources people trust. When the State Department cites their findings, it signals that the evidence for sanctions isn’t only classified intelligence that the public can’t verify, but documented facts that independent organizations have confirmed.

This creates conflict. Human Rights groups want tougher consequences for perpetrators, which creates pressure on the State Department to act. But they also worry about broader sanctions that might harm ordinary Iranians. During the January crisis, some organizations that supported sanctions against individual perpetrators raised concerns about the shadow banking designations, arguing that disrupting Iran’s financial infrastructure could worsen economic conditions for civilians already facing hardship.

Officials handle this by separating sanctions on individual perpetrators from sanctions on entire industries. The January 15 designations included both, but Treasury emphasized that the shadow banking networks were specifically involved in laundering regime funds rather than facilitating ordinary commerce.

Targeting Decisions: Who Gets Sanctioned and Why

Ali Larijani’s designation was straightforward. As Secretary of Iran’s Supreme Council for National Security, he held a documented position of authority in coordinating the government’s response to protests. The State Department didn’t need to prove he personally ordered specific killings. His role in the chain of command was sufficient.

Provincial commanders presented a different challenge. Mohammad Reza Hashemifar and Nematollah Bagheri in Lorestan, Azizollah Maleki and Yadollah Buali in Fars—weren’t well-known figures. They were mid-level military commanders whose names appeared in intelligence reports and human rights documentation as responsible for security operations in specific geographic areas where documented killings occurred.

To sanction these commanders, officials needed to link them to specific killings. Treasury said security forces in Lorestan shot civilians, security forces in Fars Province conducted mass arrests, and specific atrocities occurred in particular cities. The commanders bore responsibility because they controlled the security forces in those areas during the time those abuses occurred.

This approach sanctions people based on their position and location, not on proving they gave orders. It reflects what officials can prove when dealing with security forces operating under conditions of strict secrecy. Proving a commander gave the order to shoot would require intercepted communications or testimony from soldiers under them, neither of which is typically available. Proving a commander controlled forces in an area where killings happened is possible through military records and intelligence.

The internet blackout made even this more difficult. Without real-time information about which units were deployed where, the State Department relied more heavily on pre-blackout intelligence and on information about standing command structures. If a commander normally controlled security forces in an area where documented killings happened, officials assumed responsibility unless evidence showed otherwise.

Shadow Banking: Following the Money

The eighteen entities designated on January 15 for involvement in shadow banking networks served a different purpose in the sanctions strategy. These entities didn’t commit violence. They laundered money for the regime’s security forces, breaking existing sanctions.

Nikan Pezhvak Aria Kish Company was the central hub—the main company coordinating the network. It had processed transactions worth billions of dollars for Iran’s National Oil Company, the Islamic Revolutionary Guard Corps, and the Central Bank of Iran. The network operated through fake companies across many countries, using fake invoices to hide money transfers.

Treasury’s financial investigators track money flows and ownership to map these hidden networks that look like regular trading companies but move sanctioned money through the international financial system. Designating these entities blocks one way the regime gets around sanctions. By designating these companies and their owners, the U.S. cuts them off from international banking. Banks that work with designated entities face penalties, including losing access to U.S. financial systems.

Treasury said money laundered through these networks funds both the regime’s crackdown on protesters and its support for terrorist groups abroad. By cutting off money to the regime, the U.S. aims to limit what the security forces can spend.

Iran has spent years developing ways to get around sanctions. The regime has other ways to move money and doesn’t rely heavily on international banks. Designating these entities slows the regime down but doesn’t stop it from moving money. The shadow banking designations make it harder and more expensive for the regime to evade sanctions. Each blocked network forces the regime to find new ways to move money, which costs more. Over time, blocking these networks can reduce how much money the regime has available.

Lessons from the 2022 Mahsa Amini Protests

The State Department had coordinated sanctions during Iranian protests before. The 2022 protests after Mahsa Amini died in police custody resulted in at least 481 deaths according to human rights organizations, with some estimates running higher.

The U.S. response in 2022 included sanctions, but they took longer to announce. Designations took weeks or months, compared to days in 2026. There were fewer high-level meetings and less coordination with Europe.

The 2022 protests happened while Biden was trying to restart negotiations on the Iran nuclear deal. Tough sanctions would have made it harder to negotiate. The Trump administration didn’t have those concerns. It had already abandoned nuclear talks and wanted the toughest possible sanctions.

The internet blackout in 2026 made action more urgent than in 2022. When information gets out, the international community can document abuses and build cases slowly. When the regime cuts off information, officials have less time to gather evidence before it disappears. Officials knew that without documenting abuses right away, it would be harder to identify perpetrators later. The regime would have time to intimidate witnesses and destroy evidence.

By 2026, the government had simplified the process for imposing sanctions quickly. Treasury had experienced staff who understood the legal requirements for sanctions. Intelligence agencies could identify which Iranian security officials were responsible. This expertise, built over years, enabled faster action in 2026.

The Limits of Targeted Sanctions

These officials probably didn’t keep much money in international banks. Their money was probably in Iran or hidden through shell companies. Travel bans didn’t matter because these officials rarely left Iran anyway. Blocking U.S. trade was mostly symbolic since they had little U.S. business anyway.

This illustrates the difference between targeting individuals and targeting entire economies. The January 2026 sanctions focused on individuals, not the broader economy. Without broader economic sanctions, these individual sanctions had limited impact on the regime’s ability to crack down.

State Department officials disagree about which approach works better. Some argue that broad economic sanctions are needed to force the regime to change. Others say targeted sanctions avoid hurting ordinary Iranians. History shows neither approach reliably stops the behavior. Broad sanctions can devastate economies without forcing the regime to change. Targeted sanctions don’t always stop the violence that triggered them.

What sanctions mainly do is send a signal. They show the world is paying attention, identify perpetrators, and impose costs. Victims care that someone noticed what happened. Perpetrators might hesitate knowing they’ve been identified and face more sanctions. But deterrence only works if people care about the consequences. Iranian security officials committed to violence and loyal to the regime fear appearing weak more than sanctions.

The Evidence Problem: Sanctions in the Dark

The internet blackout raised a problem: could officials prove the designations were justified? Courts usually defer to executive branch decisions on foreign policy. The legal standard is flexible enough to give officials room to act. But officials know designated people can sue to overturn the decision.

The tight timeline meant officials needed solid evidence that the designations were justified. Lawyers documented evidence showing each person met the legal requirements for sanctions. But what counts as proof when the regime blocks information about what happened? Normally officials use multiple sources, but the blackout eliminated most of them. Officials relied more on pre-blackout intelligence and regime statements.

The blackout forced officials to work with less information. The designations went ahead with less detailed evidence than usual. During crises, you work with what you have, not what you want. Waiting for perfect evidence means no one gets held accountable.

What Coordination Achieves

By January 15, the regime had killed protesters, cut off the internet, arrested thousands, and threatened to execute detainees. The sanctions came days after the peak of the violence. Sanctions couldn’t prevent the killings.

The January 2026 process showed that when leaders want to act and countries cooperate, sanctions can be imposed quickly. Years of experience let officials create detailed sanctions packages quickly. The State Department brings together intelligence, law, diplomacy, and human rights documentation to create policy.

But the process also showed real limits. The blackout showed how hard it is to gather evidence of ongoing killings. The fact that perpetrators have few international assets suggests sanctions may not work. Even the fast response came days after the peak of the violence.

What sanctions do is create a record identifying perpetrators and showing who’s responsible. It shows the world was paying attention. When governments kill without consequences, that record matters—not because it prevents future killings, but because it shows someone was watching.

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