On July 30, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated five individuals and seven entities for helping to procure various components, including accelerometers and gyroscopes, which are key goods sought for use in Iran’s ballistic missile and unmanned aerial vehicle (“UAV”) programs. According to OFAC, the designees are based in Iran, the People’s Republic of China (“PRC”) and Hong Kong, and they procured electronics and equipment on behalf of Iranian end users, including subsidiaries of Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”). The MODAFL has been designated in the United States since 2007 in connection with Iran’s ballistic missile program. More specifically, the new designees allegedly procured equipment on behalf of MODAFL subordinates, including the Aerospace Industries Organization (“AIO”) that oversees Iran’s ballistic missile programs and subsidiaries of Iran Electronic Industries (“IEI”), an entity that has contributed to the development of UAVs in Iran. According to OFAC, the AIO and IEI were previously designated by the United States in 2005 and 2023, respectively.
The sanctions were imposed pursuant to Executive Order 13382, which targets those involved in the proliferation of weapons of mass destruction and their supporters. 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.