On April 19, 2023, the US Department of the Treasury’s Office of Foreign Assets Control designated members of a sanctions evasion network that facilitated the procurement of electronics, including components used in unmanned aerial vehicles (UAVs), for the Pardazan System Namad Arman (“PASNA”), a destabilizing military program in Iran. OFAC reports that PASNA was designated in 2018 pursuant to Executive Order 13382, which targets weapons of mass destruction proliferators and their supporters. PASNA was sanctioned for supporting Iran Electronics Industries, a subordinate to Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”). The new designees include Iranian national Mehdi Khoshghadam, PASNA’s managing director, and six front companies or suppliers based in Iran, Malaysia, Hong Kong and the People’s Republic of China that allegedly procured goods and technology for PASNA. The new designations were imposed pursuant to Executive Order 13382. OFAC also updated PASNA’s designation to include its alias, Faraz Tejarat Ertebat Company, and the aliases of fictional companies used by PASNA and Khoshghadam, Sino Trader Co., and Pouyan Electronic Co.
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. In addition, entities owned 50 percent or more by one or more blocked persons are also blocked.