OFAC / Quad Shield Guidance on Iran UAVs

Treasury's Office of Foreign Assets Control (OFAC) has published Guidance to Industry on Iran’s UAV-Related Activities.

The The 12 page document advises industries on how to avoid violations of sanctions and export controls, particularly related to Iran's UAV activities:

1. Compliance Programs: The Office of Foreign Assets Control (OFAC) encourages businesses to develop and maintain a sanctions compliance program to ensure they follow regulations and avoid any violations.

2. Voluntary Disclosures: The Department of Justice’s National Security Division (NSD) encourages industries to voluntarily disclose any potential criminal violations of U.S. national security laws, including sanctions and export control laws, to avoid criminal exposure.

3. Cooperation: If industries cooperate fully, disclose violations voluntarily, and take timely and appropriate remedial steps, there is a presumption of obtaining a non-prosecution agreement and not having to pay a fine unless there are aggravating factors.

4. Export Restrictions: The Department of Commerce's Bureau of Industry and Security (BIS) has laid out strict export control regulations. Violations can result in denial of export privileges, placement on the Entity List, and suspension of license exceptions, among other penalties.

5. Understand the Consequences: Penalties for non-compliance can be severe, including imprisonment, significant fines, denial of export privileges, and reputational damage.

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