On October 18, 2023, the US designated 11 individuals and 8 entities located in Iran, Hong Kong, the People’s Republic of China (“PRC”) and Venezuela, and identified one vessel, for enabling Iran’s ballistic missile and unmanned aerial vehicle (“UAV”) programs. According to the Office of Foreign Assets Control of the US Department of the Treasury, the designated persons have materially supported the production and proliferation of missiles and UAVs by Iran’s Islamic Revolutionary Guard Corps (“IRGC”), the Ministry of Defense and Armed Forces Logistics (“MODAFL”), or their subsidiaries. The sanctions were imposed just as UN restrictions on Iran’s missile-related activities under UN Security Council Resolution 2231 and EU restrictions on nuclear, conventional arms and missiles were set to expire. The designations were issued pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction and their supporters, and EO 13949, which targets persons involved in conventional arms activities in Iran.
The action by OFAC was part of a joint effort with the US Department of State, which designated 8 individuals and entities related to Iran’s missile, conventional arms and UAV activities. The designations also coincided with a new advisory issued by the US Departments of State, Commerce and Justice for the international community and the private sector, in particular, regarding the threat posed by Iran’s ballistic missile procurement activities. The advisory emphasizes how important it is for private companies, which are on the front line of detecting and denying Iran’s procurement efforts, to be familiar with deceptive practices used by Iranian ballistic missile procurement networks, and the key goods and technologies they seek.
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. In addition, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services to a person designated pursuant to EO 13382 could be subject to US sanctions.