April 22, 2024

U.S. and UK impose coordinated sanctions targeting Iran’s military and UAV program following the attack on Israel

On April 18, 2024, the United States joined the United Kingdom to impose coordinated sanctions upon individuals and entities that have provided support for Iran’s military and UAV production program.  These actions were taken in response to Iran’s unprecedented attack on Israel on April 13, 2024 that involved the direct launch of hundreds of drones and missiles.  According to OFAC, the sanctions target new industries that generate billions of dollars of annual revenue in Iran, a majority of which come from steel exports.

The U.S. Department of the Treasury’s Office of Foreign Assets Control designated 16 individuals and 2 entities allegedly involved in the production of unmanned aerial vehicles (“UAVs”) for Iran or the special engines used to power the Shahed UAVs that were reportedly used in the April 13 attack.  Among the designees are several executives of companies involved in Iran’s UAV production, including three executives associated with the Oje Parvaz Mado Naffar Company that manufactures engines for the Shahed-131 and Shahed-136 and the managing director of Aseman Pishraneh Co. Ltd, a company also designated by OFAC that services small aircraft engine models used in several types of Iranian UAVs.  OFAC also designated senior members of the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”) responsible for Iran’s UAV production arm; members of Kimia Part Sivan Company (“KIPAS”) responsible for improving the IRGC-QF’s UAV program; and several steel companies involved in the production of UAVs or the proliferation of UAV components, including one of Iran’s largest steel producers Khuzestan Steel Company (“KSC”).  OFAC also re-designated Iranian automaker Bahman Group along with three of its subsidiaries.

The OFAC designations were imposed pursuant to the counterterrorism authority Executive Order 13224, as amended; the counter proliferation authority EO 13382; and EO 13871 that authorizes sanctions upon those in Iran’s iron, steel, aluminum, and copper sectors.  In addition to these designations, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) concurrently imposed controls that further restrict Iran’s access to low-level technologies – restrictions that apply to items manufactured outside of the United States that are produced using U.S. technology.

On the same day, the UK government announced that it imposed new designations, in coordination with the United States, upon 7 individuals and 6 entities that have allegedly supported Iran’s destabilizing actions in the Middle East, including the direct attack on Israel.  The UK designations were imposed pursuant to the Iran (Sanctions) Regulation 2023 (SI 2023/1314), which subjects listed persons to travel bans and assets freezes.  According to Prime Minister Rishi Sunak, the United Kingdom sanctioned “the ringleaders of the Iranian military and forces” responsible for the attack on Israel.  In addition to the designation of Aseman Pishraneh, the United Kingdom targeted several Iranian military leaders and entities, including the Islamic Revolutionary Guard Corps Navy (“IRGC Navy”), one of Iran’s two naval forces; the Khatemolanbia Central Headquarters (“KCHQ”) responsible for the operational command and control of Iran’s military; and Major General Gholamali Rashid, the KCHQ Commander.

The UK government also reported that the IRGC Navy seized the MSC Aries, a civilian ship, in international waters and has threatened to take military action against Israel.  The United Kingdom emphasized that it unequivocally condemns Iran’s dangerous attack on Israel and calls for the immediate release of the MSC Aries and its crew.

U.S. Department of Treasury Press Release | U.S. Department of Commerce BIS Press Release | UK Government Press Release | OFSI Financial Sanctions Notice – Iran