On April 29, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated six entities and six individuals for being members of a network that procured ballistic missile propellant ingredients on behalf of Iran’s Islamic Revolutionary Guard Corps (“IRGC”). The IRGC has been designated in the United States since October 2007. The new designees, which are in based in Iran and People’s Republic of China (“PRC”), allegedly facilitated the procurement of sodium perchlorate and dioctyl sebacate (chemicals commonly used for ballistic missiles) from the PRC to the IRGC in Iran. Sodium perchlorate, in particular, is used to produce ammonium perchlorate, a chemical that has been controlled in order to limit its use in missiles and missile technology. All of the designees are affiliated with one of two newly-designated entities: Iran-based Saman Tejarat Barman Trading Company (“STB”) or PRC-based Shenzhen Amor Logistics Co Ltd. According to OFAC, STB procured sodium perchlorate for use by the IRGC, and Shenzhen Amor coordinated STB shipments occasionally using U.S.-designated companies like PRC-based E-Sail Shipping Company Limited. E-Sail Shipping was designated by the U.S. Department of State in December 2019.
The new designations were imposed pursuant to Executive Order 13382, which targets those involved in the proliferation of weapons of mass destruction and their supporters. 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 U.S. person are blocked, and U.S. 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.