OFAC: More Iran Missile & Drone Sanctions

In a move aimed at curbing Iran's ballistic missile and unmanned aerial vehicle (UAV) programs, the U.S. Treasury's Office of Foreign Assets Control (OFAC) has imposed sanctions on 11 individuals, eight entities, and one vessel spread across Iran, Hong Kong, the People's Republic of China (PRC), and Venezuela. These entities have allegedly supported Iran's Islamic Revolutionary Guard Corps (IRGC), Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the development and proliferation of missiles and UAVs.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is also publishing an Iran Ballistic Missile Procurement Advisory.

The sanctions come as the United Nations' restrictions on Iran's missile-related activities under UN Security Council Resolution 2231 (UNSCR 2231) expire. Additionally, the European Union is acting to retain nuclear, conventional arms, and missile-related restrictions on Iran, which were also set to expire today. Despite these developments, the U.S. remains committed to countering the threat posed by Iran's efforts to acquire, develop, and disseminate missiles, UAVs, and other military weapons.

Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson, emphasized the need to disrupt Iran's proliferation of UAVs and other weaponry to oppressive regimes and destabilizing actors. Nelson stated, "Iran's reckless choice to continue its proliferation of destructive UAVs and other weapons prolongs numerous conflicts in regions around the world."

Since September 2022, OFAC has issued ten rounds of designations targeting domestic production of Iran’s UAV program. The most recent  actions, taken pursuant to E.O. 13382, builds upon OFAC’s March 21, 2023and September 27, 2023 designations of UAV component procurement networks and January 6, 2023designation of QAI executives.

This coordinated action also includes new public guidance to private industry regarding Iranian missile procurement and related U.S. sanctions and export restrictions, in cooperation with the U.S. Departments of State, Commerce, and Justice.

Key Targets and Reasons for Sanctions:

1. Fanavaran Sanat Ertebatat Company (FSE): An Iran-based entity, FSE produces jam-resistant guidance systems for Iran's IRGC Aerospace Force Self-Sufficiency Jihad Organization (IRGC ASF SSJO), involved in ballistic missile research and flight test launches.

2. Saberin Kish Company: An Iran-based, IRGC-owned entity, Saberin Kish has procured components for the IRGC, including technical equipment repair and information technology software and hardware installation.

3. Lin Jinghe and Nanxigu Technology Co., Limited: Lin Jinghe, also known as Gary Lam, a China-based individual, procured electronic components for Iran's UAV program and other purposes. His Hong Kong-based company, Nanxigu, was involved in these activities.

4. Electro Optic Sairan Industries Co. (SAPA): SAPA, an Iranian company and subsidiary of Iran Electronics Industries (IEI), was involved in procuring military equipment and developing technologies for MODAFL.

5. Sarmad Electronic Sepahan Company: An Iran-based company, Sarmad, reverse-engineered Western-origin components used in Iranian-origin UAVs, including the Mohajer-6 UAV used by Russian forces in Ukraine.

6. Emily Liu and Rayan Roshd Afzar Company: These Iranian weapons proliferation networks, designated on July 18, 2017, supported Iran's Shiraz Electronics Industries (SEI) and the IRGC, respectively. Emily Liu sought to procure U.S. and Western-origin electronic components for SEI.

7. ICGOO Electronics Limited: A Hong Kong-based distributor, ICGOO provided sensitive components, including U.S.-origin goods, to Raybeam Optronics Co. Ltd. and Sunway Tech Co., Ltd., both designated on July 18, 2017.

8. Qods Aviation Industries (QAI) and Managing Director Ghasem Damavandian: QAI, a subsidiary of MODAFL's Iran Aviation Industries Organization (IAIO), produced Iran's Mohajer-series UAVs. Ghasem Damavandian coordinated QAI's UAV exports and upgrades for Venezuela.

9. Iranian Defense Minister Mohammad-Reza Ashtiani: Ashtiani oversaw MODAFL's supply of UAVs and weapons to Venezuela and managed an Iran-Venezuela oil venture financing defense projects.

10. Seyed Hojatollah Ghoreishi: As MODAFL's Deputy for Supply, Research, and Industry Affairs, Ghoreishi negotiated Iran's UAV sales and defense agreements with Venezuela.

11. Jaber Reihani: Iran's Defense Attaché in Venezuela, Reihani coordinated defense cooperation and provided assistance to Venezuela's UAV program.

12. Seyed Hamzeh Ghalandari: Ghalandari, as MODAFL's Director General for International Relations, facilitated Iran's UAV and defense-related deals with Venezuela.

13. General cargo vessel PARNIA: Historically used by MODAFL for defense exports, the PARNIA recently transported Iranian Peykaap III fast attack missile patrol boats to Venezuela.

These sanctions require the blocking and reporting of all property and interests in property of the designated individuals and entities, and transactions involving these blocked or designated persons are prohibited. Foreign financial institutions that facilitate significant transactions for these individuals or entities could also face U.S. sanctions.