On March 21, 2023, the US Department of the Treasury’s Office of Foreign Assets Control coordinated with the Federal Bureau of Investigation (“FBI”) to designate 3 individuals and 4 entities in Iran and Turkey for their roles in procuring equipment for Iran’s unmanned aerial vehicle (“UAV”) and weapons programs, including European–origin engines of UAVs. According to OFAC, the designees are members of a procurement network that operates on behalf of Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”), a group that manages several companies involved in development of UAVs and ballistic missiles in Iran. MODAFL was previously designated by the US in 2007 pursuant to Executive Order 13382, which targets weapons of mass destruction proliferators and their supporters. The 7 newly-designated persons were also sanctioned pursuant to EO 13382.
Among the designees is the Iran-based Defense Technology and Science Research Center (“DTSRC”), a company that is majority-owned by the MODAFL, as well as 3 individuals – Amanallah Paidar, Murat Bukey, and Asghar Mahmoudi – who procured equipment for the DTSCR, including marine electronics and items with UAV and defense applications. OFAC reports that Bukey, in particular, procured chemical and biological detection devices for the DTSRC and attempted to provide European-origin engines with UAV and surface-to-air missile applications to individuals associated with DTSCR. Bukey is also accused of selling more than 100 European-origin UAV engines and related accessories worth more than $1 million to companies that most likely transshipped them to Iran. Additional designations were imposed upon companies owned or controlled by the newly-designated individuals.
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. In addition, entities owned 50 percent or more by one or more blocked persons are also blocked.