Treasury Sanctions Iranian General for Afghan Heroin Trafficking

"The U.S. Treasury Department said Wednesday it sanctioned an Iranian general under the Kingpin Act for allowing Afghan narcotics traffickers to smuggle drugs through Iran. Iranian Islamic Revolutionary Guard Corps Qods Force General Gholamreza Baghbani is the chief of a Qods Force office near the Afghan border.  Treasury said he facilitated the smuggling of heroin precursor chemicals and shipments of opium through the Iranian border and into Iran in exchange for moving weapons to the Taliban on his behalf.   It’s the first time the Kingpin Act has been used against an Iranian official, Treasury said in a statement. “Today’s action exposes [Qods Force] involvement in trafficking narcotics, made doubly reprehensible here because it is done as part of a broader scheme to support terrorism,” said David Cohen, undersecretary of Treasury for terrorism and financial intelligence, in the statement."

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My comments:  There is something about this that I find very odd.  I certainly don't support Iranians, or the Taliban, or narcotics trafficking or terrorism.  And I don't doubt that Baghbani is a very bad guy.  But seriously? Let me walk through it.  The Kingpin Act is codified at 21 USC 1901 et seq.  The list of the sanctioned drug kingpins is given here.

1.  How does Treasury have jurisdiction over a non-citizen?  The answer is that they don't (except for assets in US banks).  The Kingpin Act has no effect over the person sanctioned.  Instead it prohibits US citizens from dealing with them.
2.  Is there any provision for reviewing or appealing such determination?  What if there is a businessman importing raw materials for pharmaceutical manufacturing who doesn't violate any local laws and he doesn't like his "good reputation" besmirched?  Apparently there is.  McNabb Associates in Washington DC represents people on the OFAC list.  They have some videos that look interesting.
3.  Why Treasury?  Isn't this something for the FBI or DEA or DHS?  How many agencies does it take to fight narco-terrorism?
4.  So which is he, a drug kingpin or a terrorist?  Is it all the same thing?  What terrorism is he accused of supporting - is it just because he sold weapons to the terrorists?  Is there an official list of terrorists?
5.  Is Bagbhani a state actor or an individual?  It sounds like he is acting with the consent of his state on behalf of Qods Force.  So why isn't Qods Force or the Taliban on the list?  If he is acting with the consent of his state, is this an act of war?  If he were captured, would the Geneva convention apply, or is he a terrorist, operating outside the protection of the Geneva convention?

What am I saying, what is my conclusion?  It seems like the War on Drugs has merged with the War on Terror.  Let's just call the whole thing OCO and give Treasury some of that OCO money.

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The official list of foreign terrorist organizations is given here:   Foreign Terrorist Organizations
Neither Qods Force nor the Taliban is on the list, although "Tehrik-e Taliban Pakistan (TTP)", which looks like their Pakistan affiliate, is.