On September 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated ten individuals and six entities based in Iran and Russia, including Tehran-based Iran Air, for providing ongoing military support to Russia to enable its war against Ukraine. OFAC also identified four vessels as blocked property for facilitating the delivery of weapons components and weapons systems to Russia. The designations were imposed in response to Russia’s receipt of its first shipment of close-range ballistic missiles (“CRBMs”) from Iran in early September 2024. The shipment was reportedly the result of a contract that Iran and Russia signed in 2023, that enables Iran to supply hundreds of missiles to Russia. OFAC also reported that the Russian military was recently trained on the use of Iranian CBRMs during the summer of 2024.
According to OFAC, Iran Air serves as Iran’s flagship airline and has had a history of transporting goods, including electronics and aircraft parts, for Iran’s Islamic Revolutionary Guard Corps (“IRGC”) and Ministry of Defense and Armed Forces Logistics (“MODAFL”), two U.S. designees. OFAC further reported that several U.S. international partners concurrently announced that Iran Air will not be allowed to operate in their territories in the future and were in the process of preparing designations of Iranian and Russian individuals, entities and vessels that have had a role in the provision of lethal aid to Russia. The U.S. Department of State also designated Iran Air and two other entities under Executive Order 13949, the Iran conventional arms authority, for their involvement in the proliferation of Iranian weapons to Russia. The State Department also identified five vessels as blocked property that allegedly transferred Iranian weapons systems to Russia.
The sanctions were imposed pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters; EO 13382, the weapons of mass destruction counterproliferation authority; and EO 14024, for operating in the defense and related materiel sector of the Russian economy. As a result of these designations, all property and interests in property of the designated persons 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 a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.