Judgment creditors of the Republic of Iran sought to execute upon the debt owed to Bank Melli, an instrumentality of Iran. The court affirmed the district court's decision allowing execution. The court found that Section 201(a) of the Terrorism Risk Insurance Act of 2002 ("TRIA") and Section 1610(g) of the Foreign Sovereign Immunities Act ("FSIA") allowed the judgment creditors to attach assets held by instrumentalities of state sponsors of terrorism. The court further found that Bank Melli did not enjoy sovereign immunity.
Ordinarily, execution against a sovereign is extremely difficult. But against state sponsors of terrorism, there are many additional weapons that a judgment creditor may deploy.