On October 18, the United States sanctioned 11 people, eight entities and one vessel linked to Iran’s ballistic missile and unmanned aerial vehicle (UAV) programs. They were based in Iran, Hong Kong, China and Venezuela and had materially supported the Revolutionary Guards, the defense ministry, or their subordinates. The move coincided with the expiration of U.N. restrictions on Iran’s missile program as part of U.N. Security Council Resolution 2231, which enshrined the 2015 nuclear deal.
“The United States has worked to disrupt Iran’s missile program since long before the U.N. Security Council imposed restrictions on it. We will continue to do so, using every tool at our disposal, so long as Iran poses a threat to security and stability in the Middle East region and around the world,” Secretary of State Antony Blinken said. In addition to imposing new sanctions, the Departments of Treasury, State, Commerce, and Justice issued new public guidance to private industry regarding Iranian missile procurement and related U.S. sanctions and export restrictions. The following are statements from the Treasury and State Departments followed by the advisory.
Secretary of State Blinken’s Statement
"Iran’s development, procurement, and proliferation of missiles and missile-related technology remains one of the greatest challenges to international peace and security. We see the horrific impact of Iran’s provision of missiles and unmanned aerial vehicles (UAVs) to designated terrorist organizations and militant proxies that directly threaten the security of Israel and our Gulf partners. We see the destructive result of Iran’s transfer of lethal UAVs to Russia to target critical civilian infrastructure and kill civilians in Ukraine. We remain focused on addressing Iran’s destabilizing proliferation activities, in particular its missile and UAV programs and the threats they pose to the world.
"Today, as the United Nations’ restrictions on Iran’s missile-related activities under UN Security Council Resolution 2231 expire, the United States reaffirms our commitment to utilize every tool at our disposal to counter Iran’s development, procurement, and proliferation of missiles, UAVs, and other dangerous weapons. Such tools include but are not limited to sanctions, export controls, diplomatic engagement, cooperation with private industry, and interdictions as appropriate and provided by law. We and our partners will also continue to raise our concerns at the United Nations and demand that Iran be held accountable for the destabilizing impacts of its proliferation.
"As part of our longstanding efforts to counter Iran’s missile-related activities and other destabilizing conduct, the United States is taking a number of new actions today. While the United States has already sanctioned all possible entities and individuals contained within Security Council Resolution 2231, today we are announcing additional designations on individuals and entities related to Iran’s missile, conventional arms, and UAV activities, including such activities involving Russia, the People’s Republic of China, Venezuela, and elsewhere. In coordination with the Departments of Commerce, Justice, and the Treasury, we are additionally issuing new public guidance to private industry regarding Iranian missile procurement and related U.S. sanctions and export restrictions.
"We are joined today by a broad grouping of 47 countries in the Proliferation Security Initiative in expressing our shared commitment to taking all necessary measures to prevent the supply, sale, or transfer of ballistic missile-related items, materials, equipment, goods, and technology by Iran. Further, we fully support the decision made by the European Union to retain nuclear, conventional arms, and missile-related restrictions on Iran.
"The United States has worked to disrupt Iran’s missile program since long before the UN Security Council imposed restrictions on it. We will continue to do so, using every tool at our disposal, so long as Iran poses a threat to security and stability in the Middle East region and around the world."
Treasury Department Press Release
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 11 individuals, eight entities, and one vessel based in Iran, Hong Kong, the People’s Republic of China (PRC), and Venezuela that are enabling Iran’s destabilizing ballistic missile and unmanned aerial vehicle (UAV) programs. The persons designated today have materially supported Iran’s Islamic Revolutionary Guard Corps (IRGC), Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the production and proliferation of missiles and UAVs.
“Iran’s reckless choice to continue its proliferation of destructive UAVs and other weapons prolongs numerous conflicts in regions around the world,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to take action to disrupt Iran’s proliferation of UAVs and other weapons to oppressive regimes and destabilizing actors, and we encourage the international community to do the same.”
Today’s action is taken as the UN’s restrictions on Iran’s missile-related activities under UN Security Council Resolution 2231 (UNSCR 2231) expire, and the European Union acts to retain the nuclear, conventional arms, and missile-related restrictions on Iran set to expire today under its nonproliferation sanctions regime. Despite the expiration of UNSCR 2231, the United States remains steadfast in its commitment to counter the threat posed by Iran’s procurement, development, and proliferation of missiles, UAVs, and other military weapons.
Additionally, in coordination with the U.S. Departments of State, Commerce, and Justice, we are issuing new public guidance to private industry regarding Iranian missile procurement and related U.S. sanctions and export restrictions.
OFAC is taking this action jointly with the Department of State, which is designating eight individuals and entities related to Iran’s missile, conventional arms, and UAV activities.
OFAC’s action today is being taken pursuant to Executive Order (E.O.) 13382 (“Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters”) and E.O. 13949 (“Blocking Property of Certain Persons With Respect to the Conventional Arms Activities of Iran”).
MISSILE, UAV, AND OTHER WEAPONS PROCUREMENT
Iran-based Fanavaran Sanat Ertebatat Company (FSE) produces jam-resistant guidance systems for Iran’s Islamic Revolutionary Guard Corps Aerospace Force Self-Sufficiency Jihad Organization (IRGC ASF SSJO), an organization involved in Iranian ballistic missile research and flight test launches. FSE also has contracts with the IRGC ASF SSJO to supply other electronic components. Iran-based Armin Ghorsi Anbaran (Anbaran) and Hossein Hemsi (Hemsi) are the two directors and shareholders of FSE, each with a 50 percent stake in the company. The IRGC ASF SSJO was designated pursuant to E.O. 13382 by the U.S. Department of State on July 18, 2017.
FSE is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, the IRGC ASF SSJO. Anbaran and Hemsi are being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, FSE.
Saberin Kish Company (Saberin Kish), an Iran-based, IRGC-owned company, procured components for the IRGC to repair lawful intercept and technical equipment. Additionally, Saberin Kish provided support for the installation and maintenance of information technology software and hardware for the IRGC. Alireza Matinkia (Matinkia), an Iran-based procurement agent, facilitated the shipment of Japan- and U.S.-origin, dual-use electronic components from Hong Kong to Iran in support of Saberin Kish’s procurement activities. Matinkia also coordinated the purchase of U.S.-origin electronic parts for Saberin Kish using a China-based intermediary.
Saberin Kish is being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, the IRGC. Matinkia is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Saberin Kish.
On various occasions, China-based Lin Jinghe, also known as Gary Lam, procured U.S.-, Japanese-, Swiss-, Taiwanese-, and UK-origin, dual-use circulators, amplifiers, inductors, and other electronic components for Matinkia using his Hong Kong-based company Nanxigu Technology Co., Limited (Nanxigu). Hong Kong-based Dali RF Technology Co., Limited (Dali RF) was used on multiple occasions to receive financial transfers related to Lin Jinghe’s electronic procurement activities for Iranian customers. Dali RF was also used by Matinkia to source UAV accessories and U.S.-origin aviation components.
Lin Jinghe and Nanxigu are being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Matinkia. Dali RF is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Lin Jinghe.
Electro Optic Sairan Industries Co. (SAPA), an Iranian company that is a subsidiary of Iran Electronics Industries (IEI), procured military equipment and developed technologies for MODAFL and the Iranian Regular Forces. Furthermore, SAPA contributes to the development of the Shahed-129 UAV for Iran’s Shahed Aviation Industries Research Center (SAIRC).
IEI was designated pursuant to E.O. 13382 on September 17, 2008, for being owned or controlled by MODAFL. SAIRC was designated pursuant to E.O. 13382 on November 15, 2022, for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, the IRGC ASF.
SAPA is being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, IEI.
Iran-based Sarmad Electronic Sepahan Company (Sarmad) has produced two types of components identified in Mohajer-6 UAVs downed by Ukrainian forces. The Mohajer-6 –– which maintains intelligence, surveillance, and reconnaissance (ISR) and strike capabilities –– is produced by Iran’s Qods Aviation Industries (QAI) and has been used by Russian forces in Ukraine. Sarmad reverse engineers Western-origin components, such as servomotors and flowmeters, which are then used by QAI in the production of the Mohajer-6 and other Iranian-origin UAVs. QAI was designated pursuant to E.O. 13382 on December 12, 2013 for having provided material support to MODAFL and being owned or controlled by the IRGC.
Sarmad is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, QAI.
Since September 2022, OFAC has issued ten rounds of designations targeting domestic production of Iran’s UAV program. Today’s actions, which are taken pursuant to E.O. 13382, builds upon OFAC’s March 21, 2023 and September 27, 2023 designations of UAV component procurement networks and January 6, 2023 designation of QAI executives.
EMILY LIU AND RAYAN ROSHD AFZAR COMPANY
OFAC is also sanctioning Iranian weapons proliferation networks led by Emily Liu and Rayan Roshd Afzar Company (Rayan Roshd). OFAC designated Emily Liu and Rayan Roshd on July 18, 2017 for having provided material support for Iran’s Shiraz Electronics Industries (SEI) and IRGC, respectively. Since at least 2014, Emily Liu sought to procure U.S.- and Western-origin electronic components for SEI, a MODAFL subsidiary responsible for producing various equipment including radars, avionics and control systems, and missile guidance technology for Iran’s military. Rayan Roshd has produced technical components for the IRGC’s UAV program and worked to produce software for the IRGC’s aerospace program.
PRC-based Yongxin Li, also known as Emma Lee, is an associate of Emily Liu who supported the procurement of various dual-use electronics including printed circuit boards, ultrasonic sensors, diodes, oxygen sensors, and integrated circuits on multiple occasions for Rayan Roshd. Hong Kong-based Yiu Wa Yung, also known as Stephen Yung, worked with Emma Lee to facilitate procurement and arrange shipments for Rayan Roshd.
ICGOO Electronics Limited (ICGOO), a Hong Kong-based distributor of electronic components, has provided sensitive components, including U.S.-origin goods, to OFAC-designated Raybeam Optronics Co. Ltd. (Raybeam). Raybeam, along with Sunway Tech Co., Ltd. (Sunway) and two other firms, were designated pursuant to E.O. 13382 on July 18, 2017, for having provided material support for Emily Liu and her proliferation activities.
Emma Lee is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Rayan Roshd. Stephen Yung is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Emma Lee. ICGOO is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Raybeam.
OFAC is also updating the Specially Designated Nationals (SDN) List to include additional identifying information for Emily Liu, Raybeam, and Sunway to assist the compliance community with identifying these blocked persons.
UAV AND MISSILE BOAT TRANSFERS TO VENEZUELA
Iran-based QAI is a subsidiary of MODAFL’s Iran Aviation Industries Organization (IAIO) that produces Iran’s Mohajer-series ultra-light UAVs. QAI has previously exported the Mohajer-2 UAV model to Venezuela, where it was rebranded as the “Arpia.” More recently, QAI has engaged with senior Caracas officials on the sale of Mohajer-6 UAVs and aircraft to Venezuela. As the managing director of QAI, Iran-based Ghasem Damavandian (Damavandian), has coordinated QAI’s UAV exports and upgrades for Venezuela.
QAI is being designated pursuant to E.O. 13949 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, MODAFL. It was previously designated pursuant to E.O. 13382 and E.O. 14024. Damavandian is being designated pursuant to E.O. 13949 for having acted or purported to act for or on behalf of, directly or indirectly, QAI.
Iranian defense minister Mohammad-Reza Ashtiani (Ashtiani) has overseen MODAFL’s supply of UAVs and other weapons to Venezuela. Ashtiani also manages an Iran-Venezuela oil venture that finances defense projects. Ashtiani was previously designated pursuant to E.O. 13876 on January 10, 2020, for being a person appointed to a position as a state official of Iran by the Supreme Leader of Iran.
Iran-based Seyed Hojatollah Ghoreishi (Ghoreishi), as MODAFL’s Deputy for Supply, Research, and Industry Affairs, has negotiated Iran’s UAV sales and defense agreements with Venezuela, including an arms sales agreement likely worth hundreds of millions of dollars. In connection with his role in Iran’s agreement to supply UAVs to Russia in 2022, Ghoreishi was designated pursuant to E.O. 13382 on January 6, 2023, for acting or purporting to act for or on behalf of, directly or indirectly, MODAFL and QAI.
Iran’s Defense Attaché in Venezuela, Jaber Reihani (Reihani), has coordinated Iran’s defense cooperation with Venezuela, to include the aforementioned arm sales agreement. As a representative of MODAFL, Reihani has overseen Iran’s efforts to provide assistance to Venezuela’s UAV program. Reihani has also previously served as the commercial director for QAI. Iran-based Seyed Hamzeh Ghalandari (Ghalandari), as MODAFL’s Director General for International Relations, has facilitated Iran’s UAV- and defense-related deals with Venezuela.
Ashtiani, Ghoreishi, Reihani, and Ghalandari are being designated pursuant to E.O. 13949 for having acted or purported to act for or on behalf of, directly or indirectly, MODAFL.
The general cargo vessel PARNIA has historically been used by MODAFL for defense exports to other countries. The PARNIA recently transported several Iranian Peykaap III fast attack missile patrol boats to Venezuela.
The PARNIA is being identified pursuant to E.O. 13949 as property in which MODAFL has an interest.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the individuals and entities named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. All transactions by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons are prohibited.
In addition, persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.
The power and integrity of U.S. sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s FAQ 897.
For identifying information on the individuals and entities designated today, click here.
Iran Ballistic Missile Procurement Advisory
The Department of Commerce, the Department of State, the Department of the Treasury, and the Department of Justice are issuing this advisory to alert persons and businesses globally to Iran’s ballistic missile procurement activities. This advisory includes sections on:
Deceptive techniques used by Iranian ballistic missile procurement networks (Annex 1), including efforts to obscure the identity of end-users through transaction layering, falsifying documentation, use of third countries for transshipment, and financing schemes.
Iranian ballistic missile-related entities (Annex 2), including subsidiaries of Shahid Bakeri Industrial Group (SBIG), Shahid Hemmat Industrial Group (SHIG), and other ballistic missile related entities of concern.
Key goods sought by Iran’s missile program (Annex 3), including specific types of production and testing equipment; raw materials; electronics; and guidance, navigation and control equipment.
Relevant U.S. sanctions and export control authorities (Annex 4), including the Iran, North Korea, and Syria Nonproliferation Act (INKSNA) (P.L.109-353); the Arms Export Control Act (22 U.S.C. 2778) and the Export Administration Act of 1979 (50 U.S.C. 4601 note); Executive Order (E.O.) 12938; E.O. 13382; and the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA).
Minimizing sanctions and export control risk (Annex 5), including for enforcement actions that may be undertaken pursuant to various U.S. legal authorities, including the Export Control Reform Act of 2018 (ECRA) (50 U.S.C. 4801-4852).
The United States is committed to countering Iran’s ballistic missile development and
proliferation activities, including related Iranian procurement efforts. We will hold accountable those assisting Iran’s ballistic missile program, regardless of the location or nationality of those providing the assistance. Private industry is on the front line of detecting and denying Iran’s procurement efforts, and consequently it is critical that companies be familiar with the techniques, entities, goods, and technologies involved in Iran’s ballistic missile procurement efforts. Iranian procurement networks are active in many countries, and relevant industries should be keenly aware that foreign inputs are required for Iran’s ballistic missile program to support efforts to increase the lethality and accuracy of Iran’s ballistic missile systems.
This advisory provides information specifically relevant to the private industry in both the United States and abroad on the deceptive practices, key red flags, and other important indicators of ballistic missile-related procurement efforts by Iran. The purpose of this consolidated document is to assist businesses in implementing effective due diligence policies, procedures, and internal controls relevant to Iran’s ballistic missile program, thereby ensuring full compliance with applicable U.S. legal requirements.