A/HRC/39/54 depend on RUSAL and its subsidiaries49 and the granting by the Department of Treasury Office of Foreign Assets Control of limited “licences” allowing a short deadline for Americans and persons of other nationalities to wind down their dealings with RUSAL, the chilling economic impact of the sanctions has been catastrophic. The company has seen customers stop buying its aluminium and creditors scramble to offload debt. Reuters reported that RUSAL shares had lost almost 60 per cent of their value after the imposition of sanctions, while aluminium and alumina prices had soared, hitting businesses around the world, including in the United States. The sanctions are likely to adversely affect the daily life of nearly 100,000 people employed by RUSAL across its international operations and offices in several countries, not only in the Russian Federation, and tens of thousands that depend on those jobs. It is to be stressed that those individuals bear no responsibility for the ownership structure of the company for which they are working. 43. In the view of the Special Rapporteur, it is also questionable in relation to the sanctions that Russian State officials have been blacklisted merely on the grounds of their profession: to borrow the words of the Office of Foreign Assets Control - for being an official of the Government of the Russian Federation, without any alleged or specified involvement in unlawful conduct or activities being invoked by the sanctioning State. The mere fact of being an official of the Government of the Russian Federation now seems to be deemed sufficient to be included in a list of targeted individuals, which sets an ominous precedent, and furthermore amounts to a blunt denial of human rights. The persons targeted here are punished for the conduct of other persons, which corresponds to the concept of guilt by association, which is widely rejected by modern international criminal law and human rights law.50 D. An escalation in sanctions measures 44. Also of concern is the recent designation of sanctions by the Office of Foreign Assets Control against Dena Airways, the company that operates the presidential aircraft used by the President of the Islamic Republic of Iran, Hassan Rouhani, for official travel. 51 It is to be feared that this measure, based on allegations of links with the Islamic Revolutionary Guard Corps and reported military airlifts to the Syrian Arab Republic, could lead airport service companies worldwide to decline to refuel or service the aircraft. In February 2018, an aircraft used by the Iranian Foreign Minister, Javad Zarif, to attend the Munich Security Conference, and registered with another blacklisted Iranian airline, Meraj Airways, had to be refuelled by the German military after companies refused to provide services to the aircraft, citing United States sanctions. It is also to be noted that similar designations by the Office of Foreign Assets Control have previously targeted various Iranian aviation companies, including Mahan Air, the largest airline by fleet size and number of destinations in the country, which will drastically affect the ability of the airline to continue operating its international flights. 52 Resorting to sanctions that affect the normal, safe operation of civilian aircraft is a highly questionable practice that has the potential to jeopardize air safety and the security of passengers. The Special Rapporteur is also of the view that the designation of aircraft used for official flights made by figures of the Iranian administration is totally unacceptable, owing to its direct effect, which is to prevent diplomatic intercourse among nations. The measure also contradicts the generally accepted principle of international law that State aircraft enjoy sovereign immunity. 53 In addition, it is clear that a head of State and his or her aircraft enjoy immunity and 49 50 51 52 53 14 See https://home.treasury.gov/news/press-releases/sm0365. The trend towards blacklisting ministers and high- or even low-ranking government and administration officials of sanctioned countries in an indiscriminate manner, merely on the grounds of their position or appointment (that may have been unsolicited or result from popular election) is also a matter of concern. See www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20180524.aspx. See, for example, https://home.treasury.gov/news/press-releases/sm0395. See Roger O’Keefe, “Article 3” in The United Nations Convention on Jurisdictional Immunities of States and their Property. A Commentary, Roger O’Keefe and Christian J. Tams, eds. (Oxford, Oxford University Press, 2013).