On February 2, 2024, the US Department of the Treasury’s Office of Foreign Assets Control designated a network of covert procurement entities responsible for supplying material and sensitive technology for Iran’s ballistic missile and Unmanned Aerial Vehicle (“UAV”) programs. OFAC designated four entities based in Iran and Hong Kong that are alleged members of a supply network that has operated on behalf of the Pishtazan Kovosh Gostar Boshra (“PKGB”) and its CEO and chairman Hamed Dehghan, both of which were previously designated by OFAC in 2019. According to OFAC, Dehghan and the PKGB actively support multiple Iranian military organizations, including the Islamic Revolutionary Guard Corps (“IRGC”). OFAC also designated China Oil and Petroleum Company Limited (“COPC”), a Hong Kong-based front company that has allegedly arranged contracts and engaged in the sale of hundreds of millions of dollars’ worth of Iranian commodities for the IRGC-Qods Force (“IRGC-QF”).
The newly-designated companies associated with the PKGB/Dehghan network were designated pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction and their means of delivery. OFAC designated COPC under the counterterrorism authority in EO 13224, as amended, for providing material support to the IRGC-QF. As a result of these designations, all property and interests in property of these designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. Entities owned 50 percent or more by one or more blocked persons are also blocked.