On March 20, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated members from three procurement networks that have supported Iran’s ballistic missile, nuclear, and defense programs. The networks allegedly procured chemicals and other components used in the production of weapons for Iran’s Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization (“IRGC ASF SSJL”); Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”); Iran’s Centrifuge Technology Company (“TESA”), which is linked to the Atomic Energy Organization of Iran (“AEOI”); and the Kalaye Electric Company (“KEC”). OFAC imposed the designations pursuant to Executive Order 13382, which targets proliferators of weapons and mass destruction and their means of delivery. According to OFAC, the IRGC, MODAFL, and KEC have been designated in the United States since 2007 for their connection to Iran’s ballistic missile or nuclear programs, while TESA was designated by OFAC in 2011. The IRGC ASF SSJO was also designated in the United States in 2017 pursuant to EO 13382 for engaging in ballistic missile research and flight test launches.
OFAC designated members from three networks, including a network led by Germany-based Maziar Karimi, a dual Iranian-German national that has allegedly used front companies based in Oman and Türkiye to facilitate procurements for defense end-users in Iran, including the IRGC ASF SSJL. OFAC also designated individuals and entities linked to a Türkiye-based procurement network that allegedly facilitated the production of carbon fiber for the MODAFL and its subsidiaries. Members of a third network based in Iran and Türkiye were also designated for their alleged involvement in the “procurement of proliferation-sensitive material for proscribed elements of Iran’s nuclear and other military weapons programs,” including procurements on behalf of TESA and KEC.
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.